BEFORE THE ILLINOIS POLLUTION

CONTROL BOARD

THE PREMCOR REFINING

)

GROUP INC.,

)

Petitioner,

)

v.

) PCB

_-

(CAAPP Permit Appeal)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

)

NOTICE OF FILING

TO: Ms. Dorothy M. Gunn

Clerk of the Board

Illinois Pollution Control Board

100

West

Randolph

Street

Suite

11-500

Chicago, Illinois 60601

(VIA ELECTRONIC MAIL)

PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of

the Illinois Pollution Control Board an ENTRY OF APPEARANCE OF KATHERINE

D. HODGE, ENTRY OF APPEARANCE OF MONICA T. RIOS and The Premcor

Refining Group Inc.'s PETITION FOR REVIEW and MOTION TO STAY

EFFECTIVENESS OF CAAPP PERMIT,

copies

of

which are

herewith

served upon

you.

Respectfully

submitted,

THE PREMCOR REFINING

GROUP INC.,

Petitioner,

Dated: October 24, 2006

By:/s/ Katherine D. Hodge

One of Its Attorneys

Katherine D. Hodge

Monica

T. Rios

HODGE DWYER ZEMAN

3150 Roland Avenue

Post Office Box 5776

Springfield, Illinois 62705-5776

(217) 523-4900

THIS FILING SUBMITTED ON RECYCLED PAPER

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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CERTIFICATE OF SERVICE

I, Katherine D. Hodge, the undersigned, certify that

I have served the attached

ENTRY OF APPEARANCE

OF KATHERINE D. HODGE, ENTRY

OF

APPEARANCE

OF MONICA T. RIOS, PETITION FOR

REVIEW and MOTION TO

STAY EFFECTIVENESS

OF CAAPP PERMIT upon:

Ms. Dorothy

M. Gunn

Clerk of the Board

Illinois Pollution

Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

via electronic mail on October 24, 2006; and upon:

Division

of

Legal

Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

S pringfield, Illinois

62794-9276

by depositing said documents in the

United States Mail in Springfield, Illinois, postage

prepaid, on

October

24,

2006.

/s/ Katherine D.

Hodge

Katherine

D. Hodge

P REM:013/Fil/NOF and COS - EOA Petition

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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BEFORE

THE ILLINOIS POLLUTION CONTROL

BOARD

THE PREMCOR REFINING

GROUP INC.,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

PCB

_-

(CAAPP Permit

Appeal)

ENTRY OF APPEARANCE OF KATHERINE D. HODGE

NOW COMES Katherine D. Hodge, of the law firm of HODGE

DWYER

ZEMAN, and hereby enters her appearance

on behalf of Petitioner, THE PREMCOR

REFINING GROUP INC., in the above-referenced matter.

Dated: October 24, 2006

Katherine D. Hodge

HODGE DWYER ZEMAN

3150 Roland Avenue

Post

Office Box 5776

Springfield, Illinois 62705-5776

(217) 523-4900

Respectfully submitted,

THE PREMCOR REFINING

GROUP INC.,

Petitioner,

By: /s/ Katherine D. Hodge

Katherine D. Hodge

P REM:013/Fi1/EOA-KDH

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

THE PREMCOR REFINING

GROUP INC.,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

PCB

_-

(CAAPP

Permit Appeal)

ENTRY OF APPEARANCE OF MONICA T. RIOS

NOW COMES

Monica T. Rios, of the law firm of HODGE DWYER ZEMAN,

and hereby enters her appearance on behalf of Petitioner, THE PREMCOR REFINING

GROUP INC., in the above-referenced matter.

Dated: October 24, 2006

Monica T. Rios

HODGE DWYER ZEMAN

3150 Roland Avenue

Post Office Box 5776

Springfield, Illinois 62705-5776

(217) 523-4900

Respectfully submitted,

THE PREMCOR REFINING GROUP INC.,

Petitioner,

B y:

P REM:013/FiVEOA-MTR

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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BEFORE THE ILLINOIS

POLLUTION

CONTROL

BOARD

THE PREMCOR REFINING

)

GROUP INC.,

)

Petitioner,

)

v.

) PCB

_-

(CAAPP

Permit Appeal)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

)

PETITION FOR REVIEW

NOW COMES, Petitioner,

THE PREMCOR REFINING GROUP INC.

(hereinafter "Premcor"), by and through its attorneys, HODGE DWYER ZEMAN,

pursuant to Section 40.2 of the

Illinois Environmental Protection Act (415 ILCS 5/40.2)

("Act") and 35111. Admin. Code § 105. Subpart C, and petitions the Illinois Pollution

Control Board ("Board") for review of the Clean Air

Act Permit Program ("CAAPP")

permit granted to Premcor by the Illinois Environmental Protection Agency ("Illinois

EPA") pursuant to Section 39.5 of the Act on September

19, 2006.

In support thereof, Premcor states as follows:

1.

Premcor owns and operates a petroleum bulk storage and loading terminal

in Hartford, Illinois ("Hartford

Terminal"), which is classified as a "major source" for

purposes of Title V of the federal Clean Air Act, 42 U.S.C. §§ 7401, et seq., and Section

39.5 of the Act, 415

ILCS

5/39.5.

2.

Pursuant to Section 504 of the Clean Air Act, 42 U.S.C. § 7661b(c), and

Section 39.5(5) of the Act, Premcor submitted an application for a CAAPP

permit for its

Hartford Terminal to the Illinois EPA on March 7, 1996.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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3.

A draft CAAPP permit was issued by Illinois EPA on May 27, 2004, and

Illinois EPA honored a request for a public hearing that was received by Illinois EPA

during the ensuing public comment period. This public hearing was held on July 13,

2004;

therefore, the public comment period was

extended until August 12,

2004. See

IEPA Air Pollution Control Permit Record available at

http://yosemite.epa.gov/r5/il_permt.nsf/2f3e96d539c4a2a28625666b0063b9al/a2ad6al

I

912fbe5a862565bd006d5777!OpenDocument&Highlight=O,premcor

(Oct. 24, 2006)

(hereinafter "IEPA

Permit Record").

4.

On August 2, 2004, during the above-referenced comment period,

Premcor submitted comments (attached hereto as Exhibit A) on the May 27, 2004 draft

permit.

5.

Thereafter, on August

26, 2004, Premcor

submitted a

letter

(attached

hereto as Exhibit B) intended to answer certain questions posed by the American Bottom

Conservancy regarding the May 27, 2004 draft permit.

6.

On April 3, 2006, Premcor further provided comments (attached hereto as

Exhibit C) in response to the Illinois EPA's request

for

confirmation of the storage tanks

at the Hartford Terminal.

7.

On August 3, 2006, Illinois EPA issued its "Project Summary for the Draft

Clean

Air

Act

Program (CAAPP) Permit" ("Project

Summary")

(attached hereto as

Exhibit D) for the Hartford Terminal. Illinois EPA stated that "[a]fter a review of

Premcor's application, . . . [it] made a preliminary determination that the application met

the standards for issuance of a CAAPP permit." See Project Summary at 10. Illinois

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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EPA, however, failed to address the comments that Premcor had submitted regarding the

May 27, 2004 draft permit.

8.

On or about August 3, 2006, the Illinois EPA submitted a draft CAAPP

permit

for the Hartford Terminal to the United States Environmental Protection Agency

("USEPA") for its review. See IEPA Permit Record.

9.

In addition, during the time that elapsed between issuance of the initial

draft CAAPP permit for the public comment period (May 2004) and the submission of a

subsequent draft permit

(August 2006) to USEPA for review, Premcor applied for and

received several construction permits for the Hartford Terminal. Construction permit

#04070052

(attached hereto as Exhibit E) allowed the storage and loading of ethanol and

toluene at the terminal, permit #05030053 (attached hereto as Exhibit F) allowed the

installation of 19 Lube Cube containers,

and permit #05120034 (attached hereto as

Exhibit G) allowed the installation of an on-site SVE system.

10. On September 19, 2006, Illinois EPA granted a final CAAPP permit

(attached hereto as Exhibit H) for the Premcor Hartford Terminal. However, the Illinois

EPA

failed

to make certain changes to the CAAPP permit, as requested by Premcor, as

incorporated by reference below. In addition, the Illinois EPA failed to appropriately

incorporate provisions

from the construction permits referenced above, ultimately

resulting in duplicative and inconsistent requirements.

11. Premcor hereby

incorporates

by

reference

the comments (attached

hereto

as Exhibits A, B, and C) submitted to the Illinois EPA regarding the May 2004 draft

permit.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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12. For the above-referenced reasons,

the CAAPP permit does not reflect the

current applicable requirements or the current operations of the facility, and thus is not

"consistent

with

the

Clean

Air Act and regulations

promulgated thereunder and this Act

and regulations promulgated thereunder." 415 ILCS 5/39.5. Certain conditions discussed

herein

are not required to "accomplish the purposes and provisions of this Act and to

assure compliance with applicable requirements." Id.

WHEREFORE, Petitioner, THE PREMCOR

REFINING GROUP INC. petitions

the Illinois Pollution Control Board for a hearing on the Illinois EPA's action to issue this

CAAPP permit in this fashion. And, as set forth in the accompanying

Motion to Stay

Effectiveness of CAAPP Permit, THE PREMCOR REFINING GROUP INC. requests

that the effectiveness of the

CAAPP

permit

be stayed until the

Board's

final

determination in this matter.

Respectfully submitted,

THE PREMCOR REFINING GROUP INC.,

Petitioner,

By:

/s/

Katherine

D. Hodge

One of its Attorneys

Dated: October 24, 2006

Katherine D. Hodge

Monica T. Rios

HODGE DWYER ZEMAN

3150 Roland Avenue

Post

Office

Box 5776

Springfield, Illinois 62705-5776

(217) 523-4900

P REM:013/Fil/Petition for Review V.2

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

THE PREMCOR REFINING

)

GROUP INC.,

)

Petitioner,

)

v.

)

PCB

No.

(CAAPP Permit Appeal)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

)

MOTION TO STAY EFFECTIVENESS OF CAAPP PERMIT

NOW COMES,

Petitioner, THE PREMCOR REFINING GROUP INC.

(hereinafter "Premcor"), by and through its attorneys, HODGE DWYER ZEMAN, and

hereby moves the

Illinois Pollution

Control

Board ("Board") to stay the

effectiveness

of

Premcor's Clean Air Act Permit Program ("CAAPP") permit in this matter, pursuant to

35 Ill. Admin. Code

§ 105.304(b).

In support thereof, Premcor states as follows:

1.

On September 19, 2006, the Illinois Environmental Protection Agency

("Illinois EPA") issued a final CAAPP permit (No. 96030082) for Premcor's petroleum

bulk storage and loading terminal in Hartford, Illinois.

2.

Today, October 24, 2006, Premcor has filed a Petition for Review in order

to preserve its right to appeal in this matter.

3.

A

stay

of

effectiveness

of the

CAAPP

permit is needed

to prevent

irreparable harm to Premcor and to protect Premcor's certain and clearly ascertainable

right

to appeal

permit

conditions.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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4.

The Board has determined that the Administrative Procedure Act's, 5

ILCS 100/1, et seq., provisions require, upon a party's request, a stay of a CAAPP

permit's effectiveness during an appeal of its conditions. See

Dynegy

Midwest

Generation,

Inc. v. IEPA, PCB No. 06-74 at 8 (I11.Pol.Control.Bd. Feb. 16, 2006) (citing

Borg-Warner Corp. v. Mauzy, 100 Ill. App. 3d 862,427 N.E. 2d 415 (3d Dist.

1981))(holding that under Section 10-65(b) of the APA "a stay of the effectiveness of a

renewal permit is required" and that the "original permit continues in effect until final

action on the application

by the administrative bodies charged with making the

determination"); see also Dynegy Midwest Generation, Inc. (Havana Power Station) v.

IEPA, PCB No. 06-71 at 8 (II1.Pol.Control.Bd.

Feb. 16, 2006); Dynegy Midwest

Generation, Inc. (Hennepin Power Station) v. IEPA, PCB No. 06-72 at 8

(I11.Pol.Control.Bd. Feb. 16, 2006); other similar cases

are at PCB Nos.

06-55 through

06-75 and PCB No. 07-146.

5.

The Illinois

EPA, the public, and the environment will not be harmed if a

stay is granted.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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WHEREFORE, the Petitioner, THE PREMCOR REFINING GROUP INC.,

moves the Illinois Pollution Control

Board to grant a stay of effectiveness of Premcor's

CAAPP permit until the Board's final action in this matter.

Respectfully submitted,

THE PREMCOR REFINING GROUP

INC.,

Petitioner,

By: /s/

Katherine D. Hodge

One of its Attorneys

Dated: October 24, 2006

Katherine D. Hodge

Monica

T. Rios

HODGE DWYER ZEMAN

3150 Roland Avenue

Post Office Box 5776

Springfield,

Illinois 62705-5776

(217) 523-4900

P REM:013Fi1Motion to Stay

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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-11ý

Premcor

Prernier People,

Products and Service

August 2, 2004

Mr. Brad Frost

Illinois Environmental Protection Agency

Division of Air Pollution Control

1021 North Grand Avenue East

Springfield, Illinois 62794

RE. Comments on Final Draft/Proposed CAAPP Permit No. 96030081

The Premcor Refining Group Incorporated, Hartford Distribution Center

(Facility ID No. 119050AAA)

Dear

Mr. Frost:

The Premcor Refining Group, Inc.

Delaware City Refinery

P.O. Box 7000

Delaware City, DE 19706-7000

3021834.6000

On May 27, 2004, the Illinois Environmental Protection Agency (IEPA) issued a public notice for the

proposed issuance of a Clean Air Act Permit Program (CAAPP) permit (Application No. 96030082) for

The Premcor Refining Group Inc.'s (Premcor's) Hardford Distribution Center. As provided in the public

notice, IEPA is accepting comments on the proposed CAAPP permit until August 12, 2004, which is 30

days after the public hearing date.

With

this comespondence, Premcor is providing to IEPA

comments to

the Proposed CAAPP permit as ..

well as a Supplement to Premcor's September 2003 CAAPP application. Premcor's comments are

included in the letter attachment. If there are any questions regarding the attached comments, please

contact me at (618) 254-7301 ext. 261 or Mr. Tony Schroeder of Trinity Consultants at (630) 574-9400.

Sincerely,

THE

PRBMCOR REFINING GROUP

INC.

Rdwtýl Mat

Rebecca Malloy

Environmental

Specialist

Enclosures:

Comments on the Draft Permit

Supplement to CAAPP Application

cc:

Mr. Sunil Suthar, IEPA

Mr. Ed 7acoby, Premcor

Mr. Tony

Schroeder,

Trinity Consultants

FILE

NUMBER 17o,

01,

o2-

RETAIN

IN FILE

UNTIL

170.01-OL

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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The Premcor Refining Group Inc.

Hartford Distribution Center

Comments on the Draft Permit Permit No. 96030082 -Public Comment Begins Ma 27, 2004 and Ends August 12, 2004.

C omment Page

Condition Comments &

R nested

Changes

1

4

1.3

Correction. Change from "Bill" Mallo to "Becky" Mallo as listed in the CAAPP permit application.

Update. Several of the insignificant activities listed in the original permit application are no longer present at the Hartford Distribution Center. This Condition should read:

2

8

3.1.1

"3.1.1 Activities determined by Illinois EPA to be insignificant activities, pursuant to 351AC 201.210(a)(1) and 201.211, as follows:

Lube Cube Storage Tanks"

Please see the revised

insignificant activity identification form (297-CAAPP) included in the enclosed Supplement to CAAPP application.

3

8

311

Correction. The chemical storage tank and chemical storage dram listed in this condition are insignificant activities per 35 IAC 201.210(a)(17). These activities are covered

. .

under Condition 3.1.3 and should therefore not be listed in this Condition.

Correction. Tank

80-10 is a fixed roof tank, not an external floating roof tank, as identified in the original permit application. This tank will only store fuel oil #2 and will

4

10

4.0 (Unit 03)

therefore be classified as an insignificant activity under

35 IAC

201.210(a)(11)

(Condition 3.1.3). Please seethe revised identification form (232-CAAPP - External Floating

Roof Tanks) included in the enclosed Supplement to CAAPP application.

Correction.

Tank 20-3 is a fixed roof tank, not an internal floating roof tank, as identified in the original permit application. This tank will only store fuel oil #2 and will

5

10

4.0 (Unit 04) therefore be classified as an insignificant activity under 35 IAC 201.210(axl l) (Condition 3.1.3).

Please

seethe

revised identification form (232-CAAPP - Internal Floating

Roof Tanks) included in the enclosed Supplement to CAAPP application.

Correction. Tank T-3-1 is a fixed roof tank, not an internal floating roof tank, as

identified in the original permit application. This tank will only store fuel oil #2 and will

6

10

4.0 (Unit 04) therefore be classified as an insignificant activity under 35 IAC 201.210(a)(11) (Condition

3.1.3). Please see the revised identification form (232-CAAPP - Internal Floating

Roof Tanks) included in the enclosed Supplement to CAAPP application.

Correction. Tank T-72 is an internal floating roof tank, not a fixed roof tank, as identified

in

the original

permit application. This tank will store gasoline and other organic

7

10

4.0 (Unit 04) materials with vapor pressures

less than gasoline and should therefore be included in Unit 04. Please see the revised identification form (232-CAAPP - Internal Floating Roof

Tanks) included in the enclosed Supplement

to CAAPP application.

8

11

4.0 (Unit 05)

Correction.

The anthracite/sand filters are not air emission control equipment, as identified in the draft permit, but serve to remove solids from the waste water stream. The

anthracite/sand filters should

not

be

identified as emission control equipment in the permit.

9

11

4.0 (Unit 06) Remove Condition. Please remove Unit 06 from the "Significant Emission Units" table. See comment

#25

For further explanation.

Update/Clarification. The "Gasoline Storage Tanks" regulated group has been set up to regulate tanks that store gasoline products,

which were listed as insignificant

activities in the original CAAPP application. All of the gasoline storage tanks that are

listed in section 7.8 of the draft permit have been permanently removed from the

facility, with the exception of the Gasoline Tank Wells, which continue to be

insignificant activities. Please see the revised insignificant activity identification form (297-

CAAPP) along with supporting calculations included in the enclosed Supplement to CAAPP application.

10

11

4.0 (Unit 08)

Tank A-2 should be added to this section,

however. A-2 is a

small

(24,990 gallon) horizontal fixed roof storage tank located at the river dock. This tank is used as a pressure

relief tank, where either gasoline or distillate may be temporarily stored

in the event that the product pressure in the river dock loading lines becomes too great and must be

relieved. The description of Unit 08 should be changed from "Gasoline Storage Tanks" to "Tank A-2". Please see Section

6

of

the

enclosed Supplement

to

CAAPP

application and comment #28 for additional information on this tank.

Update. VOM emissions for the purposes of fees have changed due to the reclassification of storage tanks from floating roof storage tanks able to store gasoline

to fixed

roof

11

15

5 5 1

storage tanks able

to store distillate and vice versa. Volatile Organic Material (VOM) emissions should be updated from "230.30 tpy" to "212.69 tpy" and Total Regulated

. .

Pollutant Emissions should be updated from "282.28

tpy" to

"264.67

tpy". Please see the revised CAAPP permit fee fort (292-CAAPP) included in the enclosed Supplement

to CAAPP application.

Informational. A construction permit application has been submitted by the Hartford Working Group (IEPA ID 119050AAS) that seeks authorization

to replace

the

existing

12

20-23

7 1

thermal

treatment unit (TTU) with a thermal oxidizer (TO). The TO will be operated by the Hartford Working Group under a separate CAAPP permit and therefore Premcor

.

requests that section 7.1 of this draft permit be removed when the TO has been constructed. It is anticipated that the TO

will replace the TTU

before or

soon after this draft

permit (Permit No. 96030082) becomes final.

Page 1 of 3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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The Premcor Refining Group Inc.

Hartford Distribution Center

Comments on the Draft Permit emit No. 96030082 - Public Comment Begins Ma 27, 2004 and Ends

August

12, 2004.

Comment Pa e

Condition Comments & Requested Changes

Comment Clarify condition. Please state that this annual report may be submitted with the Annual Emissions

Report using the following language.

13

23

7.1.10(b)

"The Permittee shall submit an annual report of emissions listed in Condition 71.6 with supporting calculations. The report shall include a summary of time periods when

the thermal treatment

unit flame was extinguished. This annual report maybe submitted as a supplement to the Permittee's Annual Emissions Report, which is required by

Condition 5.72. "

Clarification. Include more detail regarding the requirements of 35 IAC 219.429(c), as using the following language.

"7f

the

control device used to comply with 35IAC Section 219.762(a)(1) of this Subpart is a flare, it shall.

1) Be designed for and operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours as determined by U.S EPA

14

27

7.2.7(c)

Method 22.

2) Be operated with a pilot flame present at all times and shall be monitored with a thermocouple or any other equivalent

device

to detect the

presence of the flame.

3) Be steam-assisted, air-assisted,

or nonassisted

4) Be used only

with

the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btulscf) or greater if the flare is steam-assisted or air-assisted; or with the net

heating value of the gas being combusted being 745 AO/scm (200 Btulscf) or greater if the flare is nonassisted. "

15

28

7

.

Correction. In order to maintain continuity of the permit condition number

system, Condition

7.2.7(dxiii)

should read:

"As

an alternative to subsection

(d)(ii) of

this

Section, ... " as opposed to 'As an alternative to subsection (d)(2) of this Section, ... "

Comment - Marine Vessel Vapor Tightness. Include the following compliance option, as provided in 35 IAC 762(bx3)(B),

as Condition

7.2.7(d)(iv):

"As an alternative to subsections (d)(d) and (d)(fii) of this Section, an owner or operator ofa marine terminal

may obtain documentation as described in 35IAC 219.770(b)

16

28

7.2.7(d) that the marine vessel has been vapor-tightness tested within either the

preceeding 12 months or the preceeding 14 months, if the test is being conducted as part of the Coast

G uard's reinspection of the vessel required under 46 CFR 31.10-17, using Method 21 ofPart 60, Appendix

A,

incorporated by reference at

Section 219.112

of this Part,

as

described in Section 219.768(b) of this

Subpart.

"

1 7

28

7.2.7(f)-(g)

Comment Conditions

7.2.7(1)

and 7.2.7(g) should be relabeled

7.2.7(e)

and

7.2.7(1),

respectively, to maintain continuity of the permit condition number system.

Comments.

72.9(d)

Condition

7.2.9(d).

Hartford does not use the emissions reduction compliance option at the marine terminal. This condition does not apply to Hartford operations and

18

30-31

72.9(e)

should be removed from the permit.

Condition 7.2.9(e). This is an initial compliance certification requirement. The initial certification of existing marine terminal operations was required in 1996. This one-

time requirement has already passed, and should be removed from the operating permit.

Correction. Tank 80-10 is a fixed roof tank, not an external floating roof tank, as identified in the original permit application. Please remove this tank from the list of tanks

19

34

7.3.2

included in Unit 03, as it will only store fuel oil #2 and will therefore be classified as an insignificant activity under 35 IAC 201.210(a)(11) (Condition 3.1.3). Please see the

revised identification form (232-CAAPP - External Floating Roof Tanks) included in the enclosed Supplement to CAAPP application.

Correction. Tank 20-3 is a fixed roof tank, not an internal floating roof tank, as identified in the original permit application. Please remove this tank from the list of tanks

20

41

7.4.2

included in Unit 04, as it will only store fuel oil #2 and will therefore be classified as an insignificant activity under 35 IAC 201.210(a)(11) (Condition 3.1.3). Please see the

revised identification form (232-CAAPP - Internal Floating Roof Tanks) included in the enclosed Supplement to CAAPP application.

Correction. Tank T-3-1 is a fixed roof tank, not an internal floating roof tank, as identified in the original permit application. Please remove this tank from the list of tanks

21

41

7.4.2

included in Unit 04, as it will only store fuel oil #2 and will therefore be classified as an insignificant activity under 35 IAC 201.210(ax

11) (Condition 3.1.3). Please

see the

revised identification form (232-CAAPP - Internal Floating Roof Tanks) included in the enclosed Supplement to CAAPP application.

22

41

7 42

Correction. Tank T-72 is an internal floating roof tank, not a fixed roof tank, as identified

in the

original

permit application. Please add this tank from the list of tanks

.

included in Unit 04. Please see the revised identification form (232-CAAPP - Internal Floating Roof Tanks) included

in

the enclosed Supplement

to

CAAPP

application.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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---

The Premcor Refining Group Inc.

Hartford Distribution Center

Comments on the Draft Permit (Permit No. 96030082 - Public Comment Begins Ma 27, 2004 and Ends August 12, 2004.

Comment Page

Condition Comments & Requested Changes

23

58-61

7 .5

I nformational The HAP speciation of

VOM emissions

from the wastewater treatment plant has been updated in the enclosed Supplement to CAAPP. Please see the revised

identification form (220-CAAPP - Wastewater Treatment Plant).

24

60

7.5.5

Comment. The anthracite/sand filters are not air emissions control equipment and therefore should not be subject to periodic inspections in this permit. The filters serve as

water filters to remove solids from the waste water stream. Please remove condition 7.5.5.

Comment - Road Dust. Requires an annual calculation of PM/PM10 emissions from road traffic, and includes a requirement to keep a record of the mean vehicle weight

25

62-64

7.6

(tons) and vehicle miles traveled. Due to the low level of road dust associated with this source, this requirement is unnecessary and overburdonsome and should be removed.

Condition 5.2.2(a) of this draft permit should be adequate to regulate fugitive dust emissions from roads within the source.

26

65-71

7.7

Comment - River Dock Fugitive VOM Emissions. Please incorporate the requirements of this section into Section 7.2 (River Dock). Many of the requirements of these

two sections dealing with fugitive VOM emissions are redundant and should be combined for clarity.

Comment. Gasoline storage

tanks identified in this

section,

including two

(2) contractor

gasoline storage tanks, portable 300 gallon storage tanks, and the gasoline tank west

of the main maintenance shop are no longer owned or operated at the Hartford Distribution Center, and they should be removed from this permit.

27

72

7.8.1

The units identified as gasoline tank wells in the draft permit are part of remediation operations at the Hartford Distribution Center. They consist of 10 relatively small (500

gallon) double-walled containers that are commonly refered to as "Lube Cubes". The purpose of the each Lube Cube is to hold

hydrocarbons

(including gasoline) pumped

from vertical recovery wells until the contents can be collected by a vacuum truck and removed from the facility. Emissions of both

VOM

and HAP from these tanks are

small, so that they should be classified as insignificant under 35 IAC 201.211(a). Please see the revised insignificant activity identification form (297-CAAPP) along

with

supporting calculations included in the enclosed Supplement to CAAPP application.

Addition. Tank A-2 should be added to this section. A-2 is a small (24,990 gallon) horizontal storage tank located at the river dock. This tank is used as a pressure

relief

tank, where either gasoline or distillate may be temporarily stored in the event that the product pressure in the river dock loading lines becomes too great and

must

be

relieved. Because of its size, the only control requirement necessary for the operation of

this tank is submerged fill, as required by 35 IAC 219.122(b).

"No person shall cause or allow the loading of any organic material into any

stationary tank having a storage capacity of greater than 9461(250 gal), unless such

2

8

72-75

7.8

tank is equipped with a permanent submerged loading pipe

or

an equivalent device

approved by the Illinois EPA according to the provisions of 35 IAC 201, and further

processed consistent with Section 219.108 of this Part, or unless such tank is a pressure tank as described in 35 IAC 215.121(a) or is fitted with a recovery system as

described in 35 IAC 219.121(b)(2). "

All references to "affected

Tank Wells" in this Section should

be changed

to "affected storage tank" to reflect this change.

Comment.

The

second paragraph

of this condition is entirely informational, does not contain any permit requirements, and should therefore be removed from the permit.

29

73

7.8.6

This

condition should read:

"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. "

30

78

8.6.1

Clarification. Include more detail regarding the specific types of monitoring that must be included in this report. For example, does monitoring of the river dock flare and

TTU only need to be included, or does this

report also

cover

leak inspections

and

tank inspections?

Page 3 of 3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Premcor

P remier People,

Products and Services

August 26, 2004

Mr.

Sunil Suthar

Illinois Environmental Protection Agency

Division

of Air Pollution Control

1021

North Grand Avenue East

Springfield, Illinois 62794

P remcor Alsip Distribution

Center

3600 West

131st Street

Alsip, Illinois 60803-1635

FILE

N UMBER

RETAIN

IN

FILE UNTIL

Re: Response to American Bottom

Conservancy Letter to IEPA (Dated

8/12/2004)

Concerning Premcor Refining

Group Hartford Distribution

Center

Draft CAAPP Permit #96030082

Dear Mr. Suthar:

This letter

is

intended

to

answer questions

concerning The

Premcor Refining Group

Inc's

(Premcor) draft Title V operating permit

for the Hartford Distribution

Center (PHDC)

posed

by the

American Bottom Conservancy (ABC)

in a letter (dated

8/12/04) addressed to

Mr. Charles

Matoesian of the Illinois Environmental

Protection Agency (IEPA).

The ABC

letter was

electronically mailed to Mr.

Tony Schroeder of Trinity

Consultants by IEPA

on August 17, 2004.

With respect

to questions where supporting information

has already been presented

to IEPA

or

questions

that are better answered by IEPA directly, references

have been

included to indicate

where this information

regarding answers to these questions

may best be

found.

ABC comment #l:

For

example, p. 38-39 of Hearing

Transcript: ABC provided a letter from

Clark (now Premcor)

to

the Agency, which we obtained through

a Freedom ofInformation `Act]

request, on tankage.

The

letter

appeared to list tanks not in the permit.

Mr. Suthar was going to

check and provide

us with

the numbers and to make sure

that tanks not included in the title

V permit are no

longer in use.

Premcor must

provide the Agency (and the

public) a complete, detailed list

of

the

tanks permitted

in

this permit, a list of all tanks that are

still owned by Premcor, including

a list of those

that have

been retired, and a list of tanks owned by Premcor

that may be used

by others. The list

must also

detail not only what can be stored in the

tank but also what cannot.

Premcor response:

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. S'unil Suthar-August 26,

2004

Page 2 of 7

A complete,

up-to-date list of tanks owned

and

operated

by

Premcor at

PHDC has been provided

to IEPA as a part of the Supplement

to CAAPP

Application that

was

submitted by Premcor in July

2004. The Supplement also includes

a list

of

materials

associated with each tank.

F ollowing is a summary of tanks included in Premcor's Supplement to CAAPP Application:

+ External Floating Roof Tanks -120-1,

120-2,

120-3, .120-4, 120-5, 120-8, 80-4, 80-5, 80-

11, 20-8, 10-20, and 5-10.

" Internal Floating

Roof Tanks -120-9, 10-5, 10-7, 10-10, T-72.

" Significant Fixed

Roof

Tanks-A-2.

"

Insignificant

Fixed Roof Tanks -120-7, 120-1.0, 120-11, T-3-1, 80-10, 20-3, and

T-57.

ABC may obtain

the Supplement through a Freedom of Information Act (FOIA) request

or by any

other means that

IEPA deems appropriate.

ABC comment #2:

We also note

that as we were leaving the building after the hearing, Steve

Mulkey,

the Premcor

representative, indicated that the map provided by IEPA at the hearing was inaccurate. Please

provide both the record and its a

diagram that is accurate

and

up-to-date.

P remcor response:

The map provided as a part of Premcor's Revised CAAPP Operating.

Permit

Application

(submitted September 2003) is accurate and up-to-date.

ABC comment

#3:

P. 42, 43: We asked which

emission sources will have a CAMplan. Mr. Suthar said he would

look at their calculations

of potential. to emit and get back to its. We do not yet have that

information and

would like to comment on it.

Premcor response:

Facilities that submitted

a complete Title V permit application prior to April 20, 1998 are required

to determine CAM

applicability and submit .information required under the CAM rule (40 CPR

Part 64) "as part of the

application :for renewal of a Part 70 [Title V] permit." (40 CFR

64.5(x)(3)). CAM applicability

for individual emission units at PHDC will be determined and

addressed as a part of Premcor's

first Title V permit renewal application, which must be submitted

within no later than 9 and no sooner than 12 months prior

to permit expiration. (Draft Permit

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

W. Sunil

Suthar-August

26, 2004

Page 3 of 7

Condition

9.1.4.)

Condition 5.2.7 of PHDC's draft CAAPP permit incorrectly states

that Premcor's original CAAPP

application was not submitted or deemed complete by April 20, 1998.

:IEPA received

Premcor's

original application for the Hartford facility on March

7, 1996 and issued an application

completeness determination to Premcor

on March 29, 1996. As such, Condition

5.2.7 of PHDC's

draft CAAPP

operating

permit

should be

corrected

by IEPA to read as follows,

This stationary source has a pollutant.-specific emissions unit that is

subject to 40 CFR

Part 64, Compliance Assurance Monitoring (CAM for Major

Stationary Sources. The

source must submit a CAMplan for each affected pollutant-specific

emissions unit upon

application

for renewal of the

initial

CAAPP permit, or upon a

significant modification to

the CAAPP

permit for the construction

or modification

of a

large pollutant

specific

emissions

unit which has the potential. post-control device emissions

of the applicable

regulated air pollutant that equals or exceeds major source threshold levels.

Premcor requests that this condition be changed in the draft CAAPP operating

permit prior to

submittal for U.S. EPA review.

ABC comment #4:

Pp. 26-29-Details of Monitoring program not yet provided. We need details

of the monitoring

program and the Agency must include language in the permit to

reflect that it has already

been

developed. We also ask that the, permit include periodic updating

of

the program.

Premcor response:

The fugitive

leak monitoring plan required

by 35 IAC 219.446 is already in place at PHDC.

The

details

of the requirements of

the

monitoring plan are included in Condition 7.7.8

of the draft

permit. Decisions regarding

updates to

wording in the permit are the responsibility

of IEPA, but

must reflect

regulatory guidelines.

ABC comment #5:

P. 71-73

Har^

ford

Village

Trustee Don Jacoby

asked about underground gasoline storage

wells.

Premcor's Mr. JVlulkey was going to check to see if there were arty underground

tanks. We have

not heard the answer to that question. The permit indicates

a "contractor

gasoline

storage tank

gasoline, ...gasoline tank wells.... "

Which contractor?

Is

it covered in this permit? Do the wells

belong to Premcor? What is

underground? Are they covered by this

permit.? Given the history of leaking and contamination

at this

site-and given that there is

no

Agency inspecting the tanks, nothing under ground

should be

allowed to continue to operate.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

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Mr. Sunil Suthar-August26, 2004

Page 4 of 7

Prencor response:

The "gasoline tank wells" that were referenced in the latest version of PHDC's draft

CAAPP

permit (dated May 27, 2004) are the "Lobe Cubes" that are described in the

Supplement to

CAAPP Application that was submitted to IEPA in July 2004.

Additionally, there are no

contractor gasoline

storage

tanks located at

PHDC, as reflected in

PHDC's Supplement to CAAPP Application.

A BC comment #6:

p. I6-Premcor Environmental Remediation Mgr.

Steve

Mulkey: "We typically employ 15-20 ficll-

time contractors at the site. "

What do the contractors do? Is everything they do covered by this permit? Is there any other

permit that covers what they do? The permit must assure that all activities undertaken by Premcor

and its contractors that are covered by applicable requirements are included in this permit.

Premcor response:

Contractors that work on-site at PHDC include pipe fitters, laborers, secretarial help, and

personnel who perform basic mechanical and electrical tasks. These contractors do not perform

tasks that would be characterized as "significant" activities that are not already listed in PHDC's

CAAPP application.

A

BC

comment

#7:

We would like to submit for the record answers to other questions we asked of Premcor's

environmental retnediation

manager, Steve Mulkey, who called its after the hearing with

answers.

We appreciate Alr. Mulkey's

prompt attention to our requests. Mr. Alulkey indicated that

none of

the tanks currently contain MTBE

and

should

not in the future. We would litre this to

be written

into the permit, because AITBE

would raise the amount

of

YOM and

HIPS emissions. It could.

also exacerbate and accelerate the groundtivater contamination.

Premcor response:

As of

July2004, MTBE has been banned in .Illinois with the exception of de minimus amounts in

gasoline product. The Premcor refineries that supply, in large part, the Hartford Distribution

Center, do not use MTBE.

ABC continent #8:

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. Sunil Suthar- August 26, 2004

Page 5 of 7

P. 70: In

view

of

the fact that the

Hartford area has a pool of petroleum/gasoline products

floating in the groundwater, whose fumes migrate into the homes of Hartford residents

and have

caused explosions AND, that no state or federal agency is inspecting the tanks

that are the

subject of this permit, we asked Prerncor if they would share

the API tank inspection reports with

us.

Mr.

2vfulkey asked,

but

reported in his

phone call to us that the company declined,

because of

pending lawsuits. Surely,

there must

be some action the Agency or EPA could take that would

allow them

to inspect these

tanks. At a minimum,

the fact that Premcor did not disclose the tank

inspection reports should be

noted in the permit

and it should be made clear that the permit

shield

does not cover any tank breakdowns and maý6mctions attributable to structural problems.

Premcor response:

As stated

previously, the CAAPP permit application is complete and contains all

of the relevant

information

oil

the tanks for purposes of the permit at issue. Premcor follows

industry standard

API 653 -for

tank integrity. These records are not relevant to a CAAPP

permit.

ABC comment #9:

We have requested but not yet received

the

latest annual emissions report for the company, and

specifically for the tanks, and are therefore unable to comment. As soon as we receive the

report,

we will

send

our comment.

Premcor response:

Premcor

submitted

its Annual Emissions Report for the 2003 reporting year to .IEPA

in April of

2004. This information may be obtained through a TOIA request or by other means that

IEPA

deems appropriate.

ABC comment #10:

The permit needs to require Prerncor

to

USE the submerged loading pipe, it is not enough to say

that they have one.

Premcor response:

The language in CAAPP permits that require that affected tanks be equipped with a permanent

submerged loading pipe is taken from the regulations of the Illinois Administrative Code.

Modifications to

the language of th is permit requirement are under the discretion of IEPA.

ABC comment #11:

We are also extremely

unclear about which company

and/or entity uses each of the wastewater

treatment facilities with regard to Prerncor, Conoco, Roxana, etc. Please provide us a

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. Sunil

Suthar-

August 26, 2004

Page

6

of

7

clarification. It was indicated at the hearing that Premcor has an NPDES'permitfor

the facility.

Please provide its with the permit number and expiration date.

Prerncor response:

P remcor's wastewater treatment facilities are used

to

treat

stone water and non-rain event

water,

including:

" Groundwater,

" Tank bottom water,

" Tank cleaning water,

" Hydrostatic test water,

" Boiler and cooling tower blowdown water (from Conoco-Phillips); and

" Small miscellaneous sources including water from pump cleanings, truck washings,

etc.

These uses are the same that are stated in PHDC's revised CAAPP Operating

Permit Application

(submitted September 2003) and in PHDC's Supplement to CAAPP

Application (submitted July

2004).

ABC comment 412:

The following appears not

to

be included in this permit. Why is it not? We request that

it be

added.

5.2.3 No person shall use any single or multiple compartment effluent water separator which

receives effluent water containing 7571/day (200 gal/day) or more of organic material fi

om

any

equipment processing, refining, treating, storing or handling organic material unless

such effluent

water separator is equipped

with

air pollution control equipment capable of reducing by

SS

percent or more the uncontrolled organic material emitted to the atmosphere.

Exception.- If no

odor nuisance exists the limitations of this subsection shall not apply

if the vapor

pressure

of the

organic material is

below 17.24

kPa (2.5

psia) at 294.3"K

(70"F) (35 IAC 21& 141(a)].

Premcor response:

The Hartford Distribution

Center is

not

subject to

35 IAC 218.141(a), as it is only applicable to

stationary sources located within

the

Chicago Nonattainment Area. The analogous requirement

for

the Metro East area is 35 1AC 219.141(a), for which applicability has already been addressed in

the draft CAAPP permit. Condition 7.5.4(d) (Non-Applicability of Regulations

of Concern) of

PI IDC's draft

CAAPP

permit states that the affected wastewater treatment

operations at PHDC do

not meet the applicability

threshold (200 gal/day

of organic

material)

for

this

requirement, as listed

in 35 IAC 219.141(a) and

determined from Premcor's

Revised CAAPP Permit Application

(September 2003) and Supplement to CAAPP

Application

(July 2004).

ABC comment #13:

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. StutiI Suthar - August 26, 2004

Page 7 of 7

We are concerned that. Premcor is not required to keep

a

detailed

record of HAPS emissions.

We

also request this condition, taken from another permit., to be added:

5.6.2

Records

for

VOM and HA P Emissions

The Permittee shall maintain records of the

following

items

to

verify that

the source is not a

major

source for HAP emissions and therefore

not subject

to 40 CFR 63Subpart R - National Emission Standards for Gasoline Distribution

Facilities (Bulk

Gasoline Terminals and Pipeline Breakout Stations) and to quanta annual

VOMemissions, so as

to demonstrate compliance with the limits in Condition 5.5.a. General Records:

i. The

identification and properties of each organic liquid

stored

at the source,

as related to emissions,

i.

e.,

vapor pressure and molecular weight; ii.

The

vapor

weight

percent

of each HAP in the

organic

material emissions for each

liquid

determined as the average over the annual range

of

storage temperature and

representative

data on the composition of the liquid, with identification

of supporting documentation,

e.g.,

USEPA 1992 survey; and FINAL DRAFT/PROPOSED

CAAPP RENEWAL PERMIT Equilon Enterprises, LLCI. D. No.: 197810AAA Application

No.:

95060055 March

26,

2004.

P remcor response:

Condition 5.7.3 of PHDC's draft

CAAPP permit

requires that Premcor report the annual

individual

and combined

HAP

emissions from the facility on a 12-month rolling basis with the

facility's Annual Emissions Report. In order to complete these reports, detailed records

of HAP

emissions must be retained. Thus, adding another requirement to the permit that states that

Premcor must keep records of HAP emissions is redundant.

We hope that the abovexesponses will help to clear tip any remaining questions concerning

PHDC's draft CAAPP operating permit. We are particularly concerned, in response to

ABC

comment #3, that Condition 5.2.7 is revised to accurately reflect the situation for PHDC.

If IEPA

has

any

questions

regarding

these responses, please contact me Becky Malloy (618)

254-7301 ext.

261

or Mr. Tony Schroeder

of Trinity Consultants at (630) 574-9400.

Sincerely,

THE PREMCOR

REFINING

GROUP INC.

ýfhomas

Mr-°'

Environmen Health and Safety. Engineer

cc:

Mr.

Brad Frost, IEPA

Mr.

Tony

Schroeder, TrinityConsultants

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

,.ýL \ALERO

P

?

ost

W

Office

ENERGY

Box 696000

CORPORATION

- San Antonio, Texas 78269-6000

J ohn Tenison, PG - HSE Manager

Loqistics Operations and Development

Phone: 2101345-4665 - Fax: 2101370-4665

E-mail: john.tenison@valero.com

April 3, 2006

CERTIFIED MAIL

NO. 7005-1160-0001-8565-6049

RETURN RECEIPT REQUESTED

Mr. Sunil Suthar

Illinois

Environmental Protection Agency

Division of Air Pollution Control - Permit Section

1021 North Grand Avenue

East

Springfield, Illinois 62794-9276

RE:

Updated

List of Storage

Tanks

The Premcor Refining Group Inc.

Premcor Hartford Distribution Center

Source ID: 119050AAA

Dear Mr. Suthar:

This letter is in response to your

request via email on March 13, 2006 to Mr. Tony Schroeder of Trinity Consultants

for confirmation

of

the storage

tanks at the Premcor Refining Group Inc.'s (Premcor) Hartford Distribution Center

(PHDC). Table

1

contains

a list of tanks at PHDC that Premcor requests be included in the pending Clean Air Act

Permit

Program

(CAAPP)

permit. The tanks listed in Table 1 are identical to those submitted to the Illinois

Environmental

Protection Agency (IEPA) in a CAAPP Operating

Permit Application

Supplement

in

July

2004.

TABLE 1. CURRENT PRODUCT STORAGE TANKS

Tank

ID

Capacity

(barrels)

Roof Type

5-10

5,000

External Floating Roof

10-5

10,000 Internal Floating Roof

10-7

10,000 Internal Floating Roof

10-10

10,000

Internal Floating Roof

10-20

10,000 External Floating Roof

20-3

20,000 Cone Roof

20-8

20,000

External

Floating

Roof

80-4

80,000 External Floating Roof

80-5

80,000 External Floating Roof

80-10

80,000

Cone Roof

80-11

80,000 External Float'n Roof

120-1

120,000 External Floating Roof

V 81 59.p65

Tank

ID

Capacity

1 20-2

(barrels)120,000

External

Roof

Floating

Type

Roof

120-3

120,000 External

Floating Roof

120-4

120,000 External Floating Roof

120-5

120,000 External Floating Roof

120-7

120,000 Cone Roof

120-8

120,000 External Floating Roof

120-9

120,000 Internal Floating Roof

120-10 120,000

Cone Roof

120-11 120,000 Cone Roof

A-2

595

Horizontal Fixed Roof

T-3-1

3,000

Cone

Roof

T-72

_

1,500 Internal Floating Roof

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. Sunil

Suthar

Page

2

April 3, 2006

Several tanks that were

listed on the insignificant activities

form (297-CAAPP) in the July 2004

CAAPP Operating

Permit Application Supplement

have been demolished or are planned to be

demolished,

however. These tanks and their demolition

status are listed in Table 2 below.

TABLE 2. TANKS REMOVED

OR TO BE REMOVED

Tank

11)

Description

Demolition Status

T-57

Diesel Storage

Scheduled for

Demolition

No

T-14ID_4

Sent

Sodium

Caustic

HypochlorideStorage

Demolished

Storage

Demolished

No

ID

Caustic Storage

Demolished

There are also

currently several waste

water storage tanks in existence

at the terminal. These tanks

have the

following designations:

T-66, T-67, T-68, T-69, T-70,

T-71, DAF, 161, and 162.

These

tanks

are properly identified in Section

7.5 of the draft CAAPP

permit (#96030082) as portions

of the

wastewater treatment system.

If you have any questions

regarding this letter,

please do not hesitate to call

me at (210) 345-4665 or

Mr. Tony Schroeder

of Trinity Consultants

at (630) 574-9400.

John Tenison

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

---

Mr. Sunil Suthar

Page 3

April 3, 2006

cc:

Steve Haug

Andy Szabo

Massoud Modarres

Tony Schroeder

- Trinity Consultants

File

O AVLD -

Logistics Operations & Development\EV

- Environmental Services\EV-12-00

Terminals\Product Terminals (PT)\HRT

-

Hartford\42 Title V Operating Permit\Storage

Tank List Itr 04-03-06.doc

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

BUREAU

OF AIR

DIVISION

of AIR POLLUTION CONTROL

PERNIIT SECTION

PROJECT SUMMARY for the

DRAFT CLEAN AIR ACT PERMIT PROGRAM

(CAAPP) PERMIT

The Premcor Refining Group, Inc. - Hartford Distribution

Center

201 East Hawthorne

Hartford, Illinois 62048

Illinois EPA ID Number: 119050AAA

Application Number: 96030082

Application Type: Initial Permit

Start of

Public

Comment Period: May 27, 2004

Close of Public

Comment Period: August 12, 2004

Permit Engineer/Technical Contact:

Sunil Suthar, 217/782-2113

Community Relations/Comments

Contact: Brad Frost, 217782-7027

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

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I. INTRODUCTION

This source applied for a Clean Air Act Permit Program (CAAPP) operating permit for

its existing operation on March 7, 1996. The CAAPP is the program established in

Illinois for the operating permits for significant stationary sources required by the federal

Clean Air Act, as amended in 1990. The conditions in this CAAPP permit are enforceable

by both the Illinois Environmental Protection Agency (Illinois EPA) and the USEPA.

The Premcor Refining Group, Inc. – Hartford Distribution Center is located at 201 East

Hawthorne, Hartford, Illinois. The source is engaged in petroleum storage and

distribution operations.

The facility was formerly Clark Refining and is now owned and operated by Premcor

Refining Group. All refinery operations are shutdown. This facility constists only of

storage and distribution operations.

II. EMISSION UNITS

Significant emission units at this source are as follows:

Emission

Unit

Description

Date

Constructed/Modified

Emission Control

Equipment

Unit 01 Vapor Control System: Control

Boreholes, Knock Out Drum,

Vacuum Blowers (75 Hp/Electric)

1/92

Thermal Treatment Unit

(Enclosed Flare)

Unit 02

Marine Vessel Loading

1981

a

Vapor Recovery Unit

and Flare

Unit 03 External Floating Roof Tanks:

120-1

120-2

120-3

120-4

120-5

120-8

80-4

80-5

80-10

80-11

20-8

10-20

5-10

1947

1947

1953

1953

1953

1957

1945

1949

1953

1953

1960

1961

1954

Floating Roof, Primary

Seal and Rim-Mounted

Secondary Seal,

Submerged Loading

Internal Floating Roof Tanks:

Group 1 Tanks

b

(Subject to 40

CFR 60, Subpart Kb):

20-3/840,000 Gal

10-10/420,000 Gal

1948/1990

1941/1994

Group 2 Tanks (Not Subject to

NSPS):

10-5/420,000 Gal

10-7/420,000 Gal

T-3-1/126,000 Gal

1941

1941

1956

Unit 04

Group 3

c

(Subject to 40 CFR

60, Subpart K) Tank:

120-9/5,040,000 Gal

1975

Internal Floating

Roof, Submerged

Loading

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Emission

Unit

Description

Date

Constructed/Modified

Emission Control

Equipment

Unit 05 Wastewater Treatment Plant:

Entry Points, Two (2)

Equalization Tanks, Diffused

Air Flotation (DAF) Unit, Two

(2) Aeration Basins, Two (2)

Clarifiers, Anthracite/Sand

Filter.

1973/1994

d

Anthracite/Sand

Filters

Unit 06 Fugitive Emissions from Paved

and Unpaved Roads

---

---

Unit 07 Fugitive VOM Emissions from

Valves, Flanges, Seals, and

Miscellaneous Components

Not Available

Leak Detection and

Repair Program

Unit 08

Gasoline Storage Tanks

Pre-1990

None

Unit 09

Lube Cubes nineteen 500-

gallon double walled

containers

June 6, 2005

None

Unit 10 Storage and Barge Loading of

Ethanol and Toluene

09/2004

river dock vapor

transfer/flare system

Unit 11 Soil Vapor Extraction System:

Blowers, Ancillary Equipment

1/2006

Thermal Oxidizer

a

Refurbished in 1981. A new platform was constructed, a new

pipeline was installed to the river dock. The loading berth was

reconditioned and all new piping and loading arms installed.

b

Subject to 40 CFR 60, Subpart Kb

c

Subject to 40 CFR 60, Subpart K

d

Installation of two (2) equalization tanks

III. EMISSIONS

This source is required to have a CAAPP permit since it is a major source of emissions.

For purposes of fees, the source is allowed the following emissions:

Permitted Emissions of Regulated Pollutants

Pollutant

Tons/Year

Volatile Organic Material (VOM)

230.30

Sulfur Dioxide (SO

2

)

4.34

Particulate Matter (PM)

12.08

Nitrogen Oxides (NO

x

)

35.56

HAP, not included in VOM or PM

----

Total

282.28

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Reported Annual Emissions

Pollutant

2005

2004

2003

CO

0.30

2.32

8.10

NOx

0.06

0.43

1.49

PM

0.24

1.95

2.01

SO2

0.31

2.51

2.45

VOM

75.11

100.11

114.19

(top

HAP)

0.37

0.40

0.53

This permit is a combined Title I/CAAPP permit that contains terms and conditions

which address the applicability, and compliance if determined applicable, of Title I of the

Clean Air Act and regulations promulgated thereunder, including 40 CFR 52.21 - Federal

Prevention of Significant Deterioration (PSD) and 35 IAC Part 203 - Major Stationary

Sources Construction and Modification. Any such terms and conditions are identified

within the permit by T1, T1R, or T1N.

EXISTING PERMITS

04070052

STORAGE & LOADING

(Section 7.10.6)

05030053

LUBE CUBES

(Section 7.9.6)

05120034

SOIL VAPOR EXTRACTION SYSTEM

(Section 7.11.6)

92050052

HARTFORD VAPOR CONTROL

(Section 7.1.6 & 7.1.7)

Any conditions established in a construction permit pursuant to Title I and not revised or

deleted in this permit, remain in effect pursuant to Title I provisions until such time that

the Illinois EPA revises or deletes them.

IV. APPLICABLE EMISSION STANDARDS

All emission sources in Illinois must comply with the Illinois Pollution Control Board’s

emission standards. The Board's emission standards represent the basic requirements for

sources in Illinois. All emission sources in Illinois must comply with the federal New

Source Performance Standards (NSPS). The Illinois EPA is administering NSPS in

Illinois on behalf of the United States EPA under a delegation agreement. All emission

sources in Illinois must comply with the federal National Emission Standards for

Hazardous Air Pollutants (NESHAP). The Illinois EPA is administering NESHAP in

Illinois on behalf of the United States EPA under a delegation agreement.

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V. PROPOSED CAAPP PERMIT

This CAAPP permit contains all conditions that apply to the source and a listing of the

applicable state and federal air pollution control regulations that are the origin of

authority for these conditions. The permit also contains emission limits and appropriate

compliance procedures. The appropriate compliance procedures may include inspections,

work practices, monitoring, record keeping, and reporting to show compliance with these

requirements. The Permittee must carry out these procedures on an on-going basis.

Non-Applicability Statements

As CAAPP permits are intended to list applicable regulatory requirements, it is inherent

that they may also identify certain requirements that are not applicable. Non-applicability

determinations or provisions are found in Conditions “7.x.5” of the permit. These

conditions include both the relevant regulatory provision or finding and the underlying

basis for the provision or finding. At one end of the spectrum, these conditions merely

reflect applicable regulatory language and are included in the CAAPP permit for clarity,

especially as CAAPP permits are prepared to be understandable by individuals who are

unfamiliar with the details of air pollution control regulations. At the other end of the

spectrum, these provisions entail the exercise of the Illinois EPA’s technical judgment

and knowledge of the historical implementation of air pollution rules in Illinois.

Unit 01: Vapor Control System

None

Unit 02: River Dock (Marine Vessel Loading):

35 IAC 219.122, which requires a submerged loading pipe when loading a volatile

organic liquid (VOL) with a vapor pressure greater than 2.5 psia, because the rule is

only relevant to loading operations for railroad tank car, tank truck, trailer, or

stationary tank; the affected marine vessel loading operation is only engaged in the

loading of marine vessels.

35 Ill. Adm. Code 219.120, Control Requirements for Storage Containers of VOL per

35 Ill. Adm. Code 219.119, which states that limitations of 35 Ill. Adm. Code 219.120

do not apply to vessels permanently attached to trucks, railcars, barges, or ships [35

Ill. Adm. Code 219.119(d)].

40 CFR 60, Subpart XX, Standards of Performance for Bulk Gasoline Terminals, since

the affected marine vessel loading does not deliver liquid product into gasoline tank

trucks as required for applicability.

40 CFR 63, Subpart Y, National Emission Standards for Marine Tank Vessel Tank

Loading Operations, since the facility has opted to accept a limit for total loading of

high-vapor pressure materials to marine vessels to no greater than 9.5 million barrels

per year; the rule requires 10 million barrels or 200 million barrels per year for

applicability.

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Unit 03: External Floating Roof Storage Tanks:

None

Unit 04: Internal Floating Roof Storage Tanks:

Groups 1 tanks and 120-9 tank are not subject to 35 IAC 219.123 when in VPL

service because they are subject to a NSPS [35 IAC 219.123(a)(5)]. Though these

tanks are subject to 35 IAC 219.121, compliance with Subpart Ka or Kb is deemed

to be more stringent and will demonstrate compliance with 35 IAC 219.121

35 IAC 219.124 because the tanks are considered internal floating roof tanks.

40 CFR Part 64, Compliance Assurance Monitoring (CAM) for Major Stationary

Sources, because the affected storage tanks uses a passive control measure, such as

a seal, lid, or roof, that is not considered a control device because it acts to prevent

the release of pollutants.

Unit 05: Wastewater Treatment System and Thermal Oxidizer:

The wastewater treatment system is not subject to the NSPS for VOC Emissions

From Petroleum Refinery Wastewater Systems, 40 CFR 60 Subpart QQQ, because

the affected wastewater treatment operations are not located at a petroleum refinery.

The wastewater treatment system is not subject to 35 IAC 219.443, Wastewater

(Oil/Water) Separator, because the affected wastewater treatment operations are not

located at a petroleum refinery.

The wastewater treatment system is not subject to 35 IAC 219 Subpart TT, Other

Emission Units, because the affected wastewater treatment operations do not meet

the applicability of 35 IAC 219.980(a). In particular, the affected wastewater

treatment operations have maximum theoretical emissions of VOM that are less

than 90.7 Mg (100 tons) per year.

The wastewater treatment system is not subject to 35 IAC 219.141(a), as applicability

requires use any single or multiple compartment effluent water separator which

receives effluent water containing 757 l/day (200 gal/day) or more of organic

material from any equipment processing, refining, treating, storing or handling

organic material; the affected wastewater treatment operations do not meet this

threshold.

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Unit 07:Fugitive VOM Emissions from Leaking River Dock Flare Components

Fugitive VOM Emissions from Leaking River Dock Flare Components are not

subject to 40 CFR 60, Subpart KKK, Standards of Performance for Equipment

Leaks of VOC From Onshore Natural Gas Processing Plants since the facility is

actually classified as a Petroleum Bulk Storage and Loading facility.

Fugitive VOM Emissions from Leaking River Dock Flare Components are not

subject to 40 CFR 60 Subpart LLL, Standards of Performance for Onshore Natural

Gas Processing since the facility is classified as a Petroleum Bulk Storage and

Loading facility.

Unit 08: Gasoline Storage Wells

The tank wells are not subject to the NSPS for volatile organic liquid storage vessels

(including petroleum liquid storage vessels) for which construction, reconstruction,

or modification commenced after July 23, 1984, 40 CFR 60 Subpart Kb, because

the affected tank well was constructed prior to 1984.

The tank wells are not subject to the requirements of 35 IAC 219.123, petroleum

liquid storage tanks, pursuant to 35 IAC 215.123(a)(2), which exempts storage

tanks with a capacity less than 151.42 m

3

.

Unit 09: Lube Cubes

The Lube Cubes are not subject to 40 CFR Part 64, Compliance Assurance

Monitoring (CAM) for Major Stationary Sources, because the affected Lube Cubes

do Lube Cubes do not use an add-on control device to achieve compliance with an

emission limitation or standard.

Unit 11: Soil Vapor Extraction System

This unit is not subject to the 40 CFR Part 63 Subpart GGGGG: National Emission

Standards for Hazardous Air Pollutants: Site Remediation because the source is not

a major source of HAP [40 CFR 63.7881(a)].

Non-applicability determinations also serve to shield a source from the requirement that

is identified as being non-applicable, at least until the circumstances of the subject

emission unit change. This is because a non-applicability determination provides the

permit shield when the Illinois EPA, in acting on the application, has determined that

other requirements specifically identified are not applicable to a source and this

determination (or a concise summary thereof) is included in this permit, as provided by

Section 39.5(7)(j) of the Environmental Protection Act. As USEPA is aware, the

availability of permit shields in Illinois’s CAAPP permits is explicitly provided for and

required by Section 504(f)(2) of the Clean Air Act. The Illinois EPA is obligated to

include provisions in a CAAPP permit that provide for permit shields when requested by

an applicant. The non-applicability statements are also used as a mechanism for permit

streamlining. Accordingly, the regulatory requirements for which the CAAPP permit is

silent and the Illinois EPA has refrained from making non

-

applicability determinations

are also important when considering this subject.

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Permit Streamlining Discussion

Ill Adm Code 219.121 requires that containers of VPL to ensure that the reservoir or

other container is a pressure tank or the container has either a floating roof or a vapor

recovery system with 85 % collection capability.

In comparison, 40 CFR 60, Subpart Ka and Kb requires that the reservoir or container

have an any of th following: an external floating roof (A fixed roof in combination with

an internal floating roof/external floating roof for Kb), a fixed roof with an internal

floating type cover equipped with a continuous closure device between the tank wall and

the cover edge, A vapor recovery system which collects all VOC vapors and gases

discharged from the storage vessel, and a vapor return or disposal system which is

designed to process such VOC vapors and gases so as to reduce their emission to the

atmosphere by at least 95 percent by weight. Note that the NSPS for tanks requires a 95

% reduction (by weight) of VOC in the atmosphere thru a vopor recovery system, while

Ill. Adm Code 219.121 requires a 85 % collection capability only.

Periodic Monitoring

The elements of periodic monitoring for specific emission units are summarized in the

CAAPP permit itself, in Conditions 7.x.12. As a general matter, the permits include a set

of work practice and inspection requirements, testing requirements, monitoring

requirements, recordkeeping requirements, and reporting requirements for each

significant emission unit to address compliance with the applicable requirements that

control emissions from the unit. To the extent that such requirements were lacking from

applicable regulations or were considered insufficient, new or additional requirements

were imposed. The result is sets of pollutant-specific periodic monitoring provisions for

the various categories of units that the Illinois EPA has determined are both necessary

and reasonable to address compliance with the emission control requirements that apply

to such units.

Generally speaking, the majority of the periodic monitoring for this facility is already

developed through the various federal regulations that apply to the facility which

encompasses predominantly recordkeeping and reporting. However, one area where

periodic monitoring had to be put into place was for the River Dock VOM emissions.

Periodic monitoring is required for the Fugitive VOM Emissions from Leaking River

Dock Flare Components. Fugitive VOM Emissions from Leaking River Dock Flare

Components are subject to 35 IAC Section 219.446 which provides that the owner or

operator of a petroleum refinery shall prepare a monitoring program plan per which

contains, at a minimum:

a.

An identification of all refinery components and the period in which each will be

monitored pursuant to Section 35 IAC 219.447 [35 IAC Section 219.446(a)];

b.

The format for the monitoring log required by 35 IAC Section 219.448 of this

Part [35 IAC Section 219.446(b)];

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c.

A description of the monitoring equipment to be used pursuant to 35 IAC Section

219.447 of this Part; and [35 IAC Section 219.446(c)]

d.

A description of the methods to be used to identify all pipeline valves, pressure

relief valves in gaseous service and all leaking components such that they are

obvious to both refinery personnel performing monitoring and Agency personnel

performing inspections [35 IAC Section 219.446(d)].

Prompt Reporting

Prompt reporting of deviations is critical in order to have timely notice of deviations and

the opportunity to respond, if necessary. The effectiveness of the permit depends upon,

among other important elements, timely and accurate reporting. The Illinois EPA,

USEPA and the public rely on timely and accurate reports submitted by the permittee to

measure compliance and to direct investigation and follow-up activities. Prompt

reporting is evidence of a permittee’s good faith in disclosing deviations and describing

the steps taken to return to compliance and prevent similar incidents.

Any occurrence that results in an excursion from any emission limitation, operating

condition, or work practice standard as specified in this CAAPP permit is a deviation

subject to prompt reporting. Additionally, any failure to comply with any permit term or

condition is a deviation of that permit term or condition and must be reported to the

Illinois EPA as a permit deviation. The deviation may or may not be a violation of an

emission limitation or standard. A permit deviation can exist even though other

indicators of compliance suggest that no emissions violation or exceedance has occurred.

Reporting permit deviations does not necessarily result in enforcement action. The

Illinois EPA has the discretion to take enforcement action for permit deviations that may

or may not constitute an emission limitation or standard or the like, as necessary and

appropriate.

Section 39.5(7)(f)(ii) of the Illinois Environmental Protection Act, which mirrors 40 CFR

70.6(a)(3)(iii)(B), requires prompt reporting of deviations from the permit requirements.

The permitting authority (in this case, Illinois EPA) has the discretion to define “prompt”

in relation to the degree and type of deviation likely to occur. Furthermore, Section

39.5(7)(f)(i) of the Illinois Environmental Protection Act, which mirrors 40 CFR

70.6(a)(3)(iii)(A) requires that monitoring reports must be submitted at least every 6

months. Therefore, USEPA generally considers anything less than 6 months to be

“prompt” as long as the selected time frame is justified appropriately (60 Fed. Reg.

36083, 36086 (July 13, 1995)).

The USEPA has stated that, for purposes of administrative efficiency and clarity, it is

acceptable to define prompt in each individual permit.

Id.

The Illinois EPA has elected to

follow this approach and defines prompt reporting on a permit by permit basis. In

instances where the underlying applicable requirement contains “prompt” reporting, this

frequency or a shorter frequency of reporting is the required timeframe used in this

permit. Where the underlying applicable requirement fails to explicitly set forth the

timeframe for reporting deviations, the Illinois EPA has developed a structured manner to

determine the reporting approach used in this permit.

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The Illinois EPA generally uses a time frame of 30 days to define prompt reporting of

most deviations. Also, for certain permit conditions in individual permits, the Illinois

EPA may require an alternate timeframe that is less than 30 days if the permit

requirement justifies a shorter reporting time period. Under certain circumstances, EPA

may establish a deviation reporting period longer than 30 days, but, in no event exceeding

6 months. Where it has established a deviation reporting period other than 30 days in an

individual permit (specifically Section 7.x.10), the Illinois EPA has explained the reason

for the alternative timeframe. (See Attachment 2 of this Project Summary.)

The timing for certain deviation reporting may be different when a source or emission

unit at a source warrants reporting to address operation, independent of the occurrence of

any deviations. This is the case for a source that is required to perform continuous

monitoring for the emission unit, for which quarterly or semi-annual “monitoring” reports

are appropriate. Where appropriate, reporting of deviations has generally been combined

in, or coordinated with these quarterly or semi-annual reports, so that the overall

performance of the plant can be reviewed in a comprehensive fashion. This will allow a

more effective and efficient review of the overall performance of the source by the

Illinois EPA and other interested parties, as well as by the source itself.

At the same time, there are certain deviations for which quicker reporting is appropriate.

These are deviations for which individual attention or concern may be warranted by the

Illinois EPA, USEPA, and other interested parties. Under this scenario, emphasis has

been placed primarily on deviations that could represent substantial violations of

applicable emission standards or lapses in control measures at the source. For these

purposes, depending on the deviation, immediate notification may be required and

preceded by a follow-up report submitted within 15 days, during which time the source

may further assess the deviation and prepare its detailed plan of corrective action.

In determining the timeframe for prompt reporting, the Illinois EPA assesses a variety of

criteria such as:

•

historical ability to remain in continued compliance,

•

level of public interest in a specific pollutant and/or source,

•

seriousness of the deviation and potential to cause harm,

•

importance of applicable requirement to achieving environmental goals,

•

designation of the area (i.e., non-attainment or attainment),

•

consistency among industry type and category,

•

frequency of required continuous monitoring reports (i.e., quarterly),

•

type of monitoring (inspection, emissions, operational, etc.), and

•

air pollution control device type and operation

These prompt reporting decisions reflect the Illinois EPA’s consideration of the possible

nature of deviations by different emission units and the responses that might be required

or taken for those different types of deviations. As a consequence, the conditions for

different emission units may identify types of deviations which include but are not

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limited to: 1) Immediate (or very quick) notification; 2) Notification within 30 days as the

standard; or 3) Notification with regular quarterly or semi-annual monitoring reports.

The Illinois EPA’s decision to use the above stated prompt reporting approach for

deviations as it pertains to establishing a shorter timeframe in certain circumstances

reflects the criteria discussed as well as USEPA guidance on the topic.

•

40 CFR 71.6(a)(3)(iii)(B) specifies that certain potentially serious deviations must

be reported within 24 or 48 hours, but provides for semi-annual reporting of other

deviations. (Serious or severe consequences)

•

FR Vol. 60, No. 134, July 13, 1995, pg. 36086 states that prompt should generally

be defined as requiring reporting within two to ten days of the deviation, but

longer time periods may be acceptable for a source with a low level of excess

emissions. (intermediate consequences)

•

Policy Statement typically referred to as the “Audit Policy” published by the

USEPA defines prompt disclosure to be within 21 days of discovery. (Standard

for most “pollutant limiting” related conditions)

•

Responses to various States by USEPA regarding other States’ definition of

prompt.

As a result, the Illinois EPA’s approach to prompt reporting for deviations as discussed

herein is consistent with the requirements of 39.5(7)(f)(ii) of the Act as well as 40 CFR

part 70 and the CAA. This reporting arrangement is designed so that the source will

appropriately notify the Illinois EPA of those events that might warrant individual

attention. The timing for these event-specific notifications is necessary and appropriate as

it gives the source enough time to conduct a thorough investigation into the causes of an

event, collecting any necessary data, and to develop preventative measures, to reduce the

likelihood of similar events, all of which must be addressed in the notification for the

deviation.

VI. REQUEST FOR COMMENTS

After review of Premcor’s application, the Illinois EPA made a preliminary

determination that the application met the standards for issuance of a CAAPP permit. The

Illinois EPA prepared a draft permit for public review. A comment period was opened on

October 10, 2003 requesting public comments. During the public comment period a

request for hearing was received.

Notification of the hearing and comment period appeared in the Alton Telegraph on May

27,2004, June 3, 2004, and June 10,2004. A hearing was held on July 13, 2004 at the

Village of Hartford Recreational Building, 715 North Delmar in Hartford. The comment

period closed on August 12, 2004.

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VII. RESPONSE TO COMMENTS

General Oversight / Compliance

Once issued, the Title V permit will be the tool to determine compliance of the facility

with environmental regulations. Enforcement comes through inspections of the facility

and reporting requirements.

At the next scheduled inspection, the inspector will verify that the facility is in

compliance with the CAAPP. Typically, scheduled inspections are performed by Agency

field staff as part of a work plan and generally are not unannounced inspections. This is

because the Illinois EPA may want to make sure that specific staff are present, that

specific records are readily available and that specific processes will be on-line or

running on that day. However, if the Illinois EPA receives a complaint or otherwise

believes that the facility may be operating out of compliance, the resulting inspection

typically will not be an announced inspection.

As discussed in Section V, reporting can be prompt or as part of scheduled reporting

activities. The company is required to promptly report upset situations to IEPA which

are then looked into by Illinois EPA compliance and inspection staff. Regular reports

that are submitted by the company are also reviewed by IEPA compliance staff to make

sure that the facility is not out of compliance.

The data that is reported is typically technical data, such as temperature of a boiler, fuel

throughput, opacity data from a monitor, etc., which is easily verifiable. The Illinois

EPA is able to more adequately assess the compliance status of the facility and gauge the

accuracy through redundant reporting mechanisms built into the permit. The accuracy of

the data is generally good, however, USEPA would be the agency to look to and see if a

statistical analysis of the accuracy of reported data has been performed. The Illinois EPA

has not seen any studies that indicate that self-reported data is routinely inaccurate. Self-

reporting is the most efficient way to ensure compliance.

CAAPP facilities, including Premcor, are required to submit an annual air emission report

and provide a compliance certification with their CAAPP application stating that they are

in compliance with all air applicable requirements. Premcor has provided certification

that they are in compliance with the rules and regulations of Title V. Section 5.1.2 of this

permit indicates that Premcor is not a major source of HAPs. Since there is no applicable

rule it is not appropriate to place a limit on or list specific HAPs. In their annual

emission report, due May 1 of each year, Premcor is required to list their HAP emissions.

Annual compliance certifications are also required and due by May 1

st

of every year.

Ambient Air Quality

The Clean Air Act of 1970 defined six

criteria pollutants

and established ambient

concentration limits to protect public health. EPA periodically has revised the original

concentration limits and methods of measurement, most recently in 1997.

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Monitoring sites report data to EPA for these six criteria air pollutants:

•

Carbon monoxide (CO)

•

Nitrogen dioxide (NO2)

•

Ozone (O3)

•

Sulfur dioxide (SO2)

•

Particulate matter (PM10 and PM2.5)

•

Lead (Pb)

(PM10 and PM2.5 are acronyms for particulate matter consisting of particles smaller than

10 and 2.5 micrometers, respectively.)

You might expect that EPA would track emissions of the same six criteria air pollutants.

But ozone is not emitted directly; it forms by chemical reactions of organic compounds

with nitrogen oxides in the air, mediated by sunlight. Lead is both a criteria air pollutant

and a hazardous air pollutant, and EPA tracks emissions of lead only as a hazardous air

pollutant. Ammonia reacts with nitric and sulfuric acids in the atmosphere to form fine

particulate matter, so EPA tracks ammonia emissions.

Thus, EPA collects emissions data for three criteria air pollutants:

•

Carbon monoxide (CO)

•

Sulfur dioxide (SO2)

•

Particulate matter (PM10 and PM2.5)

and three precursors/promoters of criteria air pollutants:

•

Volatile organic compounds (VOC)

•

Nitrogen oxides (NOx)

•

Ammonia (NH3)

There are currently three ozone monitors in the Madison Co./ St. Clair Co. area located in

Alton, Maryville and East St. Louis.

The facility is allowed to emit 230.3 tons per year of VOC as stated in 5.5.1 of the permit.

Correlating an actual VOC emission rate to a fenceline reading in parts per million

would be very difficult if not impossible to do.

From a regulatory standpoint, monitoring of ambient concentrations of HAPs is not

mandated by the Clean Air Act. Practically, it would be almost impossible to detect

individual HAP, such as benzene, with ambient air monitoring around the facility.

Gasoline is comprised of many different chemicals, with HAPs generally comprising

only about 4 to 6 percent of total gasoline emissions and benzene is only a small fraction

of that 4 to 6 percent HAP.

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Vapor Control System comments

A vapor control system is one that controls vapors from being emitted as a result of soil

contamination. This operation captures and removes hydrocarbon vapors from the

vadose zone (below ground surface). The vapor control system consists of control

boreholes, a knock out drum, vacuum blowers (75 hp/electric), and an enclosed flare

(thermal treatment unit). All vapors from the vapor control system are routed to and

through the thermal treatment unit. Wastewater treatment and vapor control, in the

context of bulk distribution, are usually separate entities.

The vapor control system described in Condition 7.1 is the same unit that was in

existence before and was constructed in '92. This is the same unit with no modifications

to date. There have been no modifications to the permit since the USEPA negotiated an

agreement with the Hartford Working Group, which includes Premcor, about

groundwater remediation.

The current vapor recovery system, consists of 12 underground vapor recovery wells that

are connected to a thermal treatment unit at the Premcor refinery. Under the current

administrative order on consent entered into between Premcor Refining Group, Equilon,

LLC, d/b/a Shell Products USA, and Atlantic Richfield Oil Company, the AOC requires

the oil companies to replace the 12 vapor recovery wells with new wells that have a

greater zone of influence. They have proposed to expand the current thermal treatment

unit and put another unit in. The only thing that has been done to the unit since 1992 is

general maintenance, replacement of some flame arrestors which were clogged, which

needed to be replaced, some upgrades of some software, the replacement of one well

through a pilot study, (the well on Birch Street), and that was replaced with a new well.

Wastewater Treatment comments

The only wastewater going to the wastewater treatment plant is storm water rainwater

run-off from the refinery operation units of Conoco and the old Premcor Refinery. The

water flows into two equalization tanks and then goes to the DAF unit, all of which is

primary separation. From the primary separation, wastewater goes to the secondary

wastewater treatment plant, which is aeration units and clarifiers. The wastewater then

gets put in a pipe and goes out to the river. The primary separation is an oil/water

separator. The first part of the wastewater treatment plant are two equalization tanks and

a solid air flotation unit, which is the oil/water separation. Once separated that oil goes

back into the refinery. Premcor has an NPDES permit for that treatment plant.

Storage Tanks comments

During the permit review, the application that was submitted by Premcor was compared

to older permits to determine what permits were in existence and the characteristics of the

tanks. Installation of a floating and secondary seals reduce emissions and are considered

installation of pollution control equipment. By definition, a modification is an increase

in emissions, so it does not become a modified tank subject to NSPS when you add an

internal floating roof or secondary seals. However, floating roofs and secondary seals are

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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what is required by NSPS, so by installing a floating roof and secondary seals, the tank is

complying with the NSPS.

In the application, Premcor indicated which tanks were in use and those were the tanks

included in the Title V permit. Any tanks in use must be included in the permit. In some

instances, construction permits are obtained for equipment which is going to be

constructed/used, but then is never brought into operation; in these cases, the facilities

usually indicate, through correspondence, that the equipment is not in use/phased out or

removed and does not need to be included in their permit. The company would need to

obtain a construction permit from the Illinois EPA to put any units back into service.

The materials allowed to be stored are based on their properties. The material must meet

the requirements of Section 7.3. The CAAPP permit requires Premcor to keep a record

of what's in each tank, how much, and what type of properties of each. Throughput is

required to be recorded, as is the inspection of seals and their conditions.

Containment systems are present to prevent land or water contamination and a

containment system would be a requirement of Land regulations not air regulations. The

air permit contains requirements that the tanks have controls such as floating roofs to

contain air emissions. Tanks in the St. Louis non-attainment area, including the ones at

this facility, must have secondary seals and floating roofs if they are to store high vapor

pressure materials. Traditional containment systems for loss to the land or water is

generally not addressed by air. Every tank would typically be required to have what they

call a berm. In other words, a wall of dirt that goes all the way around the tank or tanks,

and that's required to be large enough to contain the whole volume of material in the tank

if it ruptured plus another 10%. We don't have any RCRA or NPDES requirements in

Title V permits.

During the application review, the Illinois EPA relies on the company to accurately

describe the equipment located at the facility. At the next scheduled inspection after

permit issuance, the inspector will verify that the facility is in compliance with the

permit, including whether it has unpermitted units. At that point the CAAPP permit is a

legally actionable document and if the Illinois EPA finds that there are units at the site

not covered by the CAAPP permit the Illinois EPA may take enforcement action against

the company. The company stated at the hearing that the American Petroleum Institute

writes standards for tank inspections. The API standard for tank inspection requirements

is API 653. Under most circumstances, the company is required to inspect each tank

every ten years, including a complete internal inspection of the entire tank and a test to

determine thickness of the tank walls. Based on the inspection the tank may be returned

to service for another ten years, or it may need repairs before being returned to service.

The company stated at the hearing that they use an ultrasonic thickness gauge to measure

the thickness of the steel during the inspection. The company stated at the hearing that

tank inspections are staggered so that an API 653 inspection is done for a few tanks every

year. For more information on tank inspections the company should be contacted as the

Illinois EPA does not require and has no oversight over these types of inspections. Tank

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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inspections are not a requirement of Illinois EPA or USEPA so any tank inspection

reports would not be submitted to either agency. The facility would keep them on record.

Monitoring comments

The facility previously had a leak detection and repair program in place. This program

was actually taken from the existing state permit. Language in Title V permit states that

underlying documentation is publicly enforceable, such as monitoring programs.

The permit is a document that lays out the regulations that apply to a source. It is

renewed every five years. It is not a document that is designed to show current

compliance, that is what reports required by the permit are for. Any of these documents

may be obtained through FOIA. The monitoring program has to meet certain

requirements that are stipulated in Section 7.2.7. as well as the requirements stipulated

by IAC rules.

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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217/782-2113

I LLINOIS ENVIRONMENTAL

PROTECTION

AGENCY

P .O. Box 19506, SPRINGFIELD, ILLINOIS 62794-9506

RENEE CIPRIANO,

DIRECTOR

C ONSTRUCTION

PERMIT

FILE

N UMBER

1

7th.6

<,,

V7,G?f

PERMITTEE

RETAIN

IN

FILE

UIYT1L

The Premcor

Refining Group, Inc.

Attn: Becky

Malloy

201 East Hawthorne

Hartford, Illinois

62048

Application NO.:

04070052

I.D. No.: 119050AAA

Applicant's Designation:

Date Received: July 19, 2004

Subject: storage

and Barge Loading of Ethanol

and

Toluene

Date

Issued: September

29, 2004

Location: 201

East Hawthorne, Hartford

Permit is hereby

granted to the above-designated Permittee to CONSTRUCT

emission source(s)

and/or air pollution control

equipment

consisting of

a

project for

the storage and barge loading of ethanol and toluene, as

described in

the above-referenced application.

This

Permit is subject to

standard conditions

attached hereto and the following special condition(s):

la. i. This

permit authorizes the Permittee

to store

ethanol in the

following existing floating roof tanks: 120-1, 120-2, 120-3,

120-4, 120-5, 120-8, 80-4, 80-5,

80-11, 20-8, 10-20,

5-10, 120-9,

10-5, 10-7, 10-10, and T-72.

ii. This permit authorizes the

Permittee to store toluene

in any two

existing floating roof tanks.

Note: The Permittee may continue

to store other materials

such as

gasoline

as

authorized by

the source's operating permit(s).

b. The Permittee shall operate and

maintain tanks storing ethanol

and

toluene,

including associated control features in accordance with

good

air pollution

control practice to minimize

emissions.

C. This permit

is issued based upon no increase

in emissions

of volatile

organic

material (VON) from the storage of ethanol or toluene, as the

vapor pressures

of ethanol and toluene are

less

than the vapor pressure

of gasoline,

which is currently stored in the tanks.

d. operation

of

the storage

facility shall not exceed a toluene

throughput

o£ 300,000 barrels/month and

3,000,000 barrels/year.

2a.

This permit authorizes the Permittee

to load ethanol and

toluene at the

river

dock.

Note:

The Permittee may continue to load

other materials

such as

gasoline

at the river dock as authorized by

the source's

operating

permit(s).

ROD

R. BLAGOJEVICH, GOVERNOR

PRINTED ON RECYCLED PAPER

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

* * * * * PCB 2007-030 * * * * *

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Page 2

b . The river dock vapor transfer/flare

system shall be operated

to control

VOM

emissions from loading of ethanol and

toluene at all

times that

these materials

are being loaded at the

river dock.

c. Operation of the river dock shall

not exceed the following

limits:

Throughput

Material

(Barrels/Mo) (Barrels/Yr)

Ethanol

150,000

1,500,000

Toluene

300,000

3,000,000

d . Emissions

attributable to the loading of ethanol

and

toluene shall not

exceed

the following limits:

Emissions

Pollutant

(Tons/Mo) (Tons/Yr)

VOM

0.1

0.98

3 . The Permittee

shall maintain the following

records:

a.

Properties of the ethanol and toluene materials handled at the

facility, as needed to calculate

VOM emissions from

handling such

materials with supporting documentation.

b. Identification

and throughput (barrels/month)

for

each type of

material stored in each tank;

c. Identification and throughput

(barrels/month) of each material

loaded at the river

dock;

d. i.

VOM

emissions from the

storage of ethanol and toluene

(tons/month

and

tons/year), with supporting calculations.

ii. VOM emissions

from

the loading of

ethanol

and toluene

(tons/month and tons/year), with supporting calculations.

4.

All records

and logs required by this permit

shall be

retained at a

readily

accessible

location

at the source

for at least

three years from

the date

of entry and shall be made

available for

inspection and

copying

by the Illinois EPA upon request. Any

records

retained in an

electronic

format

(e.g.,

computer) shall be capable of being retrieved

and printed

on

paper during normal

source office hours so as to be able

to respond to an Illinois EPA request

for records during

the course of

a source inspection.

5. If there

is an exceedance of the requirements

of this permit

as

determined by the records required

by this permit, the Permittee

shall

submit

a report to the Illinois EPA

within 30 days after

the

exceedance.

The

report shall

include the

emissions

released in

accordance

with

the recordkeeping

requirements, a copy of the relevant

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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Page 3

records, and

a description

of the

exceedance or violation

and efforts

to

reduce emissions and future occurrences.

6. The

Permittee may operate the affected emission

units

as provided above

under

this permit until final action is taken on the Clean

Air Act

Permit

Program (CAAPP) application for this source.

Please note that this permit does not establish

limits on

emissions of

hazardous air pollutants (HAPs) from this modification

and

does not

address

whether

the source currently is a major source of

HAPs or

will become a major

source

of HAPs as a consequence of this modification.

If

you

have any questions on this, please call Jason

Schnepp

at 217/782-2113.

Oax"f'& Z' 5rýý

Donald E. Sutton, P.E.

Manager, Permit Section

D

ivision

of Air Pollution Control

DES:JMS:psj

cc: Region 3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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y,

..

2 17/782-2113

ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

P .O. Box 19506, SPRINGFIELD, ILLINOIs 62794-9506

RENEE

CIPRIANO,

DIRECTOR

1 70.

OI,OV

P

ERMITTEE

CONSTRUCTION

PERMIT

F ILE NUMBER

The Premcor Refining

Group, Inc.

Attn: Becky Malloy

201 East Hawthorne

Hartford,.Illinois 62048

RETAiN

N FILE

UNTIL

Application No.: 05030053

I.D. No.: 119050AAA

Applicant's Designation:

Date Received: March 14, 2005

Subject: Lube Cubes

Date Issued: June 6, 2005

Location: 201 East Hawthorne,

Hartford

This Permit is hereby granted to the above-designated

Permittee to

CONSTRUCT

emission source(s) and/or air pollution control

equipment consisting of

nineteen 500-gallon double

walled

containers

(Lobe

Cubes),

as described in

the above-referenced application.

This Permit-is subject to standard

conditions attached hereto and the

following

special

condition(s):

1.

2.

3.

4.

This permit is issued based upon

negligible

emissions

of volatile

organic material WOM) from each lube

cube. For this purpose, emissions

shall not exceed nominal emission

rates of

0.1

lb/hour and 0.18

tons/year.

Note: the lube cubes may be considered

an

insignificant

activity

under

r.

the CAAPP.

Pursuant to 35 IAC 219.121(b),

no

person

shall cause or allow the

loading of any organic

material into any stationary tank having a

storage capacity of greater than

946 1 (250 gal), unless such

tank

is

equipped with a permanent

submerged loading pipe.

Pursuant to 35 IAC

219.129(f), the owner or operator o¬ each storage

vessel specified

in

35

IAC 219.119 shall maintain readily accessible

records of the dimension

of each storage vessel and an analysis of the

capacity of the storage

vessel.

Emissions from the lube cubes and

all other

emission

units at the source

shall not exceed the following limits:

individual HAPs

Combination Of

All

HAPs

(Tons/Month)

(Tons/Year)

(Tons/Month)

(Tons/Year)

0.8

8.0

2.0

20.0

5. The Permittee shall maintain

records of the following items for each

emission unit or group of related

units that has the potential to emit

HAPs to verify that.the source is

not a major source of HAP emissions.

ROD R. BLAGOJEVICH, GOVERNOR

PRINTED oN RECYCLED PAPER

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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Page 2

a.

Emissions

of HAPs (individual and

combination of all

HAPs) from

each emission unit or group of

emission units with,

supporting

documentation

and example

calculations (tons/month

and

tons/year).

b. As an alternative to

keeping the above records, the

Permittee

may

keep a demonstration,

which shall be kept

current, that the

maximum emissions

of such operations given the

maximum level

of

activity that could

as a practical matter,

occur at the source,

would not exceed the

applicable limits in

Condition 4.

6.

All records and logs required

by this permit shall be

retained at a

readily accessible location

at the source for at least

five years

from

the date of entry and shall

be made available

for inspection and

copying by the Illinois

EPA upon request. Any records

retained

in an

electronic format (e.g., computer)

shall be capable

of being retrieved

and printed on paper during

normal source office hours

so as to be

able

to respond to an Illinois

EPA request for records

during the course

of

a source inspection.

7.

If there is an exceedance

of the requirements of

this permit as

determined by the records

required by this permit,

the Permittee

shall

submit a report to the

Illinois EPA within 30 days after

the

exceedance. The report

shall include the emissions

released in

accordance with

the

recordkeeping

requirements, a

copy of the relevant

records, and a description

of the exceedance

or

violation

and efforts

to reduce emissions and future

occurrences.

8.

The Permittee may operate the

lube cubes under this

construction permit

until final action is taken

on the Clean Air Act Permit Program

(CAAPP)

application for this source.

If you have

any questions on this, please

call Jason Schnepp

at 217/782-2113.

Donald

E. Sutton, P.E.

Manager,

Permit Section

Division of Air Pollution Control

DES:JMS:psj

CC: Region

3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY

1

021

NORTH GRAND AVENUE EAST, P.O. Box 19506, SPRINGFIELD,

ILLINOIS

62794-9506

- (

217) 782-2113

ROD R. BLAGOJEVICH, GOVERNOR

DOUGLAS

P. SCOTT, DIRECTOR

217/782-2113

CONSTRUCTION PERMIT

PERMITTEE

The Premcor Refining Group,

Inc.

Attn: Mr. Tom Mroz

2 01 East

Hawthorne

Hartford,

Illinois 62048

Application No.: 05120034

I.D. No.: 119050AAA

Applicant's Designation:

Date Received: December 19, 2005

Subject: Soil Vapor Extraction

System

Date Issued: January

24, 2006

Location: 201 East

Hawthorne, Hartford

This Permit is hereby granted

to the above-designated Permittee to CONSTRUCT

emission source(s)

and/or air pollution control equipment consisting of a

Soil Vapor Extraction

System, as described in the above-referenced

application.

This Permit is subject to standard conditions attached hereto

and the following special

condition(s):

1 .1 Soil Vapor

Extraction System

1.1.1 Description

The soil vapor extraction system

will be installed to

extract

hydrocarbon vapors present in the soil using a series of

extraction wells. The system consist

of a blower which

will

draw vapors from the wells to a thermal

oxidizer.

1 .1.2

List of Emission Units and Air

Pollution Control Equipment

Emission Control

Emission

Unit

Description

Equipment

S oil

Vapor

Blowers, Ancillary Thermal Oxidizer

Extraction S stem

Equipment

1.1.3

Applicable Provisions and Regulations

a . The "affected unit" for the purpose of these unit-specific

conditions,

is the soil vapor extraction system described

in Conditions 1.1.1 and

1.1.2.

b . ...:.. The..'.'

unit is subject

to 35 IAC Part 219, Subpart

TT: Other Emission Units.

c . ..i.. . The affected unit is subject to 35 IAC 219.301: Use

..of..Drganic..Material, which provides that:

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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No person shall cause or allow the

discharge

of more

than 3.6 kg/hr (8 lbs/hr) of organic

material

into

the atmosphere from any emission unit, except as

provided

in 35 IAC 219.302 and the following

exception: If no odor nuisance exists the limitation

of this Subpart shall apply only to photochemically

reactive material.

ii. Emissions of organic

material in excess

of those

permitted by 35 IAC

219.301 are allowable if

such

emissions are

controlled by thermal incineration

so

as either to

reduce such emissions to 10 ppm

equivalent methane

(molecular weight

16) or less, or

to convert 85

percent of the hydrocarbons to

carbon

dioxide and

water.

d.

Pursuant

to

35 IAC 212.123(a), no person shall cause

or

allow the emission of smoke or other particulate matter,

with

an opacity greater

than 30 percent, into the

atmosphere from any

emission unit other than those

emission

units subject to the requirements of 35 IAC 212.122,

except

as allowed by 35 IAC 212.123(b) and 212.124.

1 .1.4

Non-Applicability of Regulations of Concern

a .

This permit is issued based upon the affected unit not

being subject

to

the 40 CFR Part 63 Subpart GGGGG:

National Emission Standards for Hazardous Air Pollutants:

Site Remediation because the source

is not

a major source

of HAP [40 CFR 63.7881(a)].

1 .1.5

Control Requirements and Work Practices

a . The emission capture and control

equipment

shall achieve an

overall reduction in uncontrolled

VOM emissions

of at least

81 percent from each affected

unit, pursuant

to 35 IAC

2 19.986(a).

Note: this control

requirement is less stringent

than the

control requirement listed

in Condition 1.1.3(c)(ii).

b. The thermal oxidizer shall be in operation at all times

when the affected unit is in operation

and

emitting air

contaminants.

c. The

thermal

oxidizer combustion chamber shall be preheated

to at least the manufacturer's recommended temperature

but

no less than

the

temperature at which compliance was

demonstrated in the

most recent compliance

test, or 1400°F

in the absence of a compliance

test. This

temperature

shall be maintained during

operation.

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d. Natural gas shall

be the only fuel fired

in

the thermal

oxidizer.

e. The maximum gas flow rate to

the thermal oxidizer shall not

exceed 750 cfm.

1 .1.6

Production

and Emission Limitations

a .

Emissions from the affected unit

shall not exceed the

following

limits. Compliance with annual

limits

shall be

determined from

a running total of

12 months

of data.

Emissions

Pollutant

(Tons/Month)

(Tons/Year)

NO.

----

3.85

CO

0.27

3.24

VOM

----

7.84

b .

This permit is issued based

upon negligible emissions of

S02, PM and PMio from the affected

unit. For this purpose,

emissions of all such pollutants

shall not exceed a nominal

emission

rate of 0.1 lb/hour

and 0.44 tons/year combined.

1 .1.7 Testing

Requirements

a .

When in the opinion of the

Agency it is necessary to

conduct testing to demonstrate

compliance with 35 IAC

219.986, the owner or operator

of a VOM emission unit

subject to the requirements

of 35 IAC Part 219, Subpart TT

shall, at his own expense,

conduct such tests in accordance

with the applicable test

methods and procedures specified

in 35 IAC 219.105 [35

IAC 219.988(a)].

b. Nothing in 35 IAC Part

219 shall limit the authority of the

USEPA pursuant to the

Clean Air Act, as amended, to require

testing [35 IAC

219.988(b)].

1 .1.8

Monitoring

Requirements

a . The Permittee shall

use Illinois EPA

approved

continuous

monitoring equipment

which shall be installed, calibrated,

maintained, and operated

according to

vendor

specifications

at all times the afterburner

is in use. The continuous

monitoring equipment

shall monitor the combustion chamber

temperature of each afterburner.

1 .1.9

Recordkeeping

Requirements

a . The Permittee

shall collect and

record all of the

following

information

each day and maintain the

information

at the

source for a period

of three years:

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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Control device monitoring data.

ii. A log of

operating time for the capture

system,

control device,

monitoring equipment and

the

associated emission source.

iii. A maintenance log for the capture

system,

control

device and monitoring equipment

detailing

all routine

and non-routine maintenance performed including dates

and duration of any outages.

b. The Permittee shall maintain a file for

the

affected unit

documenting the following:

i. Maximum rated

exhaust flow rate from the

affected

unit, as exhausted

to the thermal oxidizer

(CFM);

ii. Maximum VOM concentration

in uncontrolled

exhaust

(ug/L) ;

iii. Maximum rated

burner capacity of the thermal

oxidizer

(mmEtu/hour);

and

iv. Potential NO,

and CO emissions from the affected

unit,

with supporting

documentation and calculations.

c. The Permittee

shall maintain records of the VOM

emissions

(tons/month

and tons/year) with supporting calculations and

documentation.

1 .1.10 Reporting Requirements

a . The Permittee shall promptly notify the Illinois EPA, Air

Compliance Unit, of deviations of an affected unit with the

permit requirements as follows. Reports shall describe the

probable

cause of such deviations, and any corrective

actions or preventive measures taken.

b. The Permittee shall notify the Illinois

EPA

in the

following instance [35 IAC 219.991(a)(3)]:

i.

Any record showing a violation of the requirements

of

35 IAC Part 219, Subpart PP, QQ, RR or TT shall be

reported by

sending a copy of such record

to the

Illinois EPA

within 30 days following the

occurrence

of the violation.

1.1.11

Operational Flexibility/Anticipated

Operating

Scenarios

operational flexibility is not set for

the

affected unit.

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Page 5

1.1.12 Compliance Procedures

a . Compliance

with

the

VOM

emission limit in Condition 1.1.6

shall be based on the recordkeeping requirements in

Condition 1.1.9 and the following equation:

VOM Emissions = Blower Discharge Rate (cfm) x 28.31685

L/cf

x 60 min/hour x VOM concentration (ug/ L) x (1/10'

kg/ug) x 2.20462 lb/kg x (1- overall control

efficiency/100)

b. Compliance with the NOX and CO emission limits

in Condition

1.1.6 shall be determined by appropriate emission

factors

and the recordkeeping requirements in Condition 1.1.9.

2. The Permittee may operate the affected unit under this construction

permit until final action is taken on the Clean Air Act Permit

Program

(CAAPP) application for this source. If this construction permit is

not incorporated into the initial CAAPP permit issued to this source,

the Permittee may operate the affected unit under this construction

permit until the CAAPP permit is reissued to address this unit.

If you have any questions on this permit, please contact Jason Schnepp

at

217/782-2113.

T>Mvý 91 -5ý7

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air

Pollution Control

DES:JMS:psj

cc: Region

3

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 24, 2006

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217/782-2113

TITLE V - CLEAN AIR ACT PERMIT

PROGRAM (CAAPP) PERMIT

and

TITLE I PERMIT'

PERMITTEE

The Premcor Refining Group, Inc. - Hartford

Distribution Center

Attn: Becky Malloy, Environmental Contact

2 01 East Hawthorne

Hartford, Illinois 62048

Application No.: 96030082

I.D.

No.: 119050AAA

Applicant's Designation:

Date Received: March 7, 1996

Operation of: Marine Terminal

Date Issued: September 19, 2006

Expiration Date 2: September

19,

2011

Source Location: 201 East Hawthorne,

Hartford, Madison County

Responsible Official: Ed Jacoby, Vice

President of Wholesale, Marketing and

Distribution

This permit is hereby granted

to the above-designated Permittee

to OPERATE a

Petroleum Bulk Storage and Loading Terminal,

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 Sunil

Suthar

at 217/782-2113.

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air Pollution

Control

DES:SIS:psj

cc: Illinois EPA, FOS,

Region 3

CES

Lotus Notes

This permit may contain terms and conditions which

address the applicability, and

compliance if determined applicable, of Title I of the

CAA and regulations promulgated

thereunder, including 40 CFR 52.21 - federal PSD and 35 IAC

Part 203 - Major Stationary

Sources Construction.and

Modification. Any such terms and conditions

are identified

within this permit.

a

Except as provided in Condition 8.7

of this permit.

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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 Compliance with Applicable Requirements

3.3 Addition of Insignificant Activities

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE

9

5.0 OVERALL SOURCE CONDITIONS

11

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

5.10 Special Permit Shield

6.0 NOT APPLICABLE TO THIS PERMIT

17

7.0 UNIT SPECIFIC CONDITIONS

18

7.1

Unit 01

:

Vapor Control System

Control: Thermal Treatment Unit (Enclosed Flare)

7.2 Unit 02: River Dock (Marine Vessel Loading)

Control: Vapor Recovery Unit

7.3 Unit 03: External Floating Roof Storage Tanks

Control: Floating Roof, Double Seals and Submerged

Loading

7.4 Unit 04: Internal Floating Roof Storage Tanks

Control: Floating Roof and Seals, Permanent Submerged

Loading

7.5 Unit 05: Wastewater Treatment System

Control: None

7.6 Unit 06: Fugitive Emissions – Paved and Unpaved Roadways

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PAGE

7.7 Unit 07: Fugitive VOM Emissions from Leaking River Dock

Flare Components

Control: Leak Detection and Repair Program

7.8 Unit 08: Gasoline Storage Tanks

Control: None

7.9 Unit 09: Lube Cubes

Control: None

7.10 Unit 10: Storage and Barge Loading of Ethanol and Toluene

Control: River Dock Vapor Transfer/Flare System

7.11 Unit 11: Soil Vapor Extraction System

Control: Thermal Oxidizer

8.0 GENERAL PERMIT CONDITIONS

83

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

8.7 Obligation to Comply with Title I Requirements

9.0 STANDARD PERMIT CONDITIONS

88

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 Requirements 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 - Significant Storage Tanks

1-1

10.2 Attachment 2 - Example Certification by a Responsible

Official

2-1

10.3 Attachment 3 – Guidance on Revising This Permit

3-1

10.4 Attachment 4 – Form 199-CAAPP, Application For

Construction Permit (For CAAPP Sources Only)

4-1

10.5 Attachment 5 – Guidance on Renewing This Permit

5-1

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1.0 SOURCE IDENTIFICATION

1.1 Source

The Premcor Refining Group, Inc. – Hartford Distribution Center

201 East Hawthorne

Hartford, Illinois 62048

I.D. No.: 119050AAA

Standard Industrial Classification: 5171, Petroleum Bulk Storage

and Loading

1.2 Owner/Parent Company

The Premcor Refining Group, Inc.

201 East Hawthorne

Hartford, Illinois 62048

1.3 Operator

The Premcor Refining Group, Inc

201 East Hawthorne

Hartford, Illinois 62048

Bill Malloy, Environmental Contact

618/254-7301 Ext. 261

1.4 General Source Description

The Premcor Refining Group, Inc. – Hartford Distribution Center

is located at 201 East Hawthorne, Hartford, Illinois. The source

is engaged in petroleum storage and distribution operations.

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2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT

Act

Illinois Environmental Protection Act [415 ILCS 5/1 et seq.]

AP-42

Compilation of Air Pollutant 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 27711

Btu

British thermal unit

CAA

Clean Air Act [42 U.S.C. Section 7401 et seq.]

CAAPP

Clean Air Act Permit Program

CAM

Compliance Assurance Monitoring

CFR

Code of Federal Regulations

ERMS

Emissions Reduction Market System

°

F

degrees Fahrenheit

ft

3

cubic feet

gal

gallon

HAP

Hazardous Air Pollutant

hp

horsepower

hr

hour

IAC

Illinois Administrative Code

I.D. No.

Identification Number of Source, assigned by Illinois EPA

ILCS

Illinois Compiled Statutes

Illinois EPA Illinois Environmental Protection Agency

°

K

degrees Kelvin

Kg

Kilogram

kPa

Kilopascals

kW

kilowatts

l

liter

lb

pound

m

3

cubic meters

mmBtu

Million British thermal units

mo

month

NESHAP

National Emission Standards for Hazardous Air Pollutants

NO

x

Nitrogen Oxides

NSPS

New Source Performance Standards

PM

Particulate Matter

PM

10

Particulate matter with an aerodynamic diameter less than or

equal to a nominal 10 microns as measured by applicable test

or monitoring methods

ppm

parts per million

PSD

Prevention of Significant Deterioration

psia

pounds per square inch absolute

RMP

Risk Management Plan

RVP

Reid Vapor Pressure

SO

2

Sulfur Dioxide

T1

Title I – identifies Title I conditions that have been

carried over from an existing permit

T1N

Title I New – identifies Title I conditions that are being

established in this permit

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T1R

Title I Revised – identifies Title I conditions that have

been carried over from an existing permit and subsequently

revised in this permit

USEPA

United States Environmental Protection Agency

VOL

Volatile Organic Liquid

VOM

Volatile Organic Material

VPL

Volatile Petroleum Liquid

wt.

weight

yr

year

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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:

Chemical Storage Tank

Chemical Storage Drum

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:

None

3.1.3 Activities that are insignificant activities based upon

their type or character, pursuant to 35 IAC 201.210(a)(4)

through (18), as follows:

Direct combustion units designed and used for comfort

heating purposes and fuel combustion emission units

as follows: (A) Units with a rated heat input

capacity of less than 2.5 mmBtu/hr that fire only

natural gas, propane, or liquefied petroleum gas; (B)

Units with a rated heat input capacity of less than

1.0 mmBtu/hr that fire only oil or oil in combination

with only natural gas, propane, or liquefied

petroleum gas; and (C) Units with a rated heat input

capacity of less than 200,000 Btu/hr which never burn

refuse, or treated or chemically contaminated wood

[35 IAC 201.210(a)(4)].

Storage tanks of organic liquids with a capacity of

less than 10,000 gallons and an annual throughput of

less than 100,000 gallons per year, provided the

storage tank is not used for the storage of gasoline

or any material listed as a HAP pursuant to Section

112(b) of the CAA [35 IAC 201.210(a)(10)].

Storage tanks of any size containing virgin or re-

refined distillate oil, hydrocarbon condensate from

natural gas pipeline or storage systems, lubricating

oil, or residual fuel oils [35 IAC 201.210(a)(11)].

Storage tanks of any size containing exclusively

soaps, detergents, surfactants, glycerin, waxes,

vegetable oils, greases, animal fats, sweeteners,

corn syrup, aqueous salt solutions, or aqueous

caustic solutions, provided an organic solvent has

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not been mixed with such materials [35 IAC

201.210(a)(17)].

3.1.4 Activities that are considered insignificant activities

pursuant to 35 IAC 201.210(b).

3.2 Compliance with Applicable Requirements

Insignificant activities are subject to applicable requirements

notwithstanding status as insignificant activities. In

particular, in addition to regulations of general applicability,

such as 35 IAC 212.301 and 212.123 (Condition 5.2.2), the

Permittee shall comply with the following requirements, as

applicable:

3.2.1 For each cold cleaning degreaser, the Permittee shall

comply with the applicable equipment and operating

requirements of 35 IAC 215.182, 218.182, or 219.182.

3.2.2 For each particulate matter process emission unit, the

Permittee shall comply with the applicable particulate

matter emission limit of 35 IAC 212.321 or 212.322. For

example, the particulate matter emissions from a process

emission unit shall not exceed 0.55 pounds per hour if the

emission unit’s process weight rate is 100 pounds per hour

or less, pursuant to 35 IAC 266.110.

3.2.3 For each organic material emission unit that uses organic

material, e.g., a mixer or printing line, the Permittee

shall comply with the applicable VOM emission limit of 35

IAC 215.301, 218.301, or 219.301, which requires that

organic material emissions not exceed 8.0 pounds per hour

or do not qualify as photochemically reactive material as

defined in 35 IAC 211.4690.

3.3 Addition of Insignificant Activities

3.3.1 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).

3.3.2 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.

3.3.3 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).

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4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Unit

Description

Date

Constructed/

Modified

Emission Control

Equipment

Unit 01

Vapor Control System:

Control Boreholes, Knock

Out Drum, Vacuum Blowers

(75 Hp/Electric)

1/92

Thermal Treatment

Unit (Enclosed

Flare)

Unit 02 Marine Vessel Loading

1981

a

Vapor Recovery Unit

and Flare

Unit 03 External Floating Roof

Tanks:

120-1

120-2

120-3

120-4

120-5

120-7

120-8

120-10

120-11

80-4

80-5

80-10

80-11

20-8

10-20

5-10

1947

1947

1953

1953

1953

---

1957

---

---

1945

1949

1953

1953

1960

1961

1954

Floating Roof,

Primary Seal and

Rim-Mounted

Secondary Seal,

Submerged Loading

Internal Floating Roof

Tanks:

Group 1 Tanks

b

(Subject to

40 CFR 60, Subpart Kb):

20-3/840,000 Gal

10-10/420,000 Gal

1948/1990

1941/1994

Group 2 Tanks (Not

Subject to NSPS):

10-5/420,000 Gal

10-7/420,000 Gal

T-3-1/126,000 Gal

1941

1941

1956

Unit 04

Group 3

c

(Subject to 40

CFR 60, Subpart K) Tank:

120-9/5,040,000 Gal

1975

Internal Floating

Roof, Submerged

Loading

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Emission

Unit

Description

Date

Constructed/

Modified

Emission Control

Equipment

Unit 05

Wastewater Treatment

Plant: Entry Points, Two

(2) Equalization Tanks,

Diffused Air Flotation

(DAF) Unit, Two (2)

Aeration Basins, Two (2)

Clarifiers,

Anthracite/Sand Filter.

1973/1994

d

Anthracite/Sand

Filters

Unit 06 Fugitive Emissions from

Paved and Unpaved Roads

---

---

Unit 07 Fugitive VOM Emissions

from Valves, Flanges,

Seals, and Miscellaneous

Components

Not

Available

Leak Detection and

Repair Program

Unit 08 Gasoline Storage Tanks

Pre-1990

None

Unit 09 Lube Cubes nineteen 500-

gallon double walled

containers

June 6, 2005

None

Unit 10 Storage and Barge Loading

of Ethanol and Toluene

09/2004

river dock vapor

transfer/flare

system

Unit 11

Soil Vapor Extraction

System: Blowers,

Ancillary Equipment

1/2006

Thermal Oxidizer

a

Refurbished in 1981. A new platform was constructed, a new

pipeline was installed to the river dock. The loading berth was

reconditioned and all new piping and loading arms installed.

b

Subject to 40 CFR 60, Subpart Kb

c

Subject to 40 CFR 60, Subpart K

d

Installation of two (2) equalization tanks

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5.0 OVERALL SOURCE CONDITIONS

5.1 Source Description

5.1.1 This permit is issued based on the source requiring a

CAAPP permit as a major source of VOM, and CO 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. No person shall cause or allow the emission of smoke or

other particulate matter, with an opacity greater than

30 percent, into the atmosphere from any emission unit

other than those emission units subject to the

requirements of 35 IAC 212.122, pursuant to 35 IAC

212.123(a), except as allowed by 35 IAC 212.123(b) and

212.124.

5.2.3 Ozone Depleting Substances

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

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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.

5.2.4 Risk Management Plan

Should this stationary source, as defined in 40 CFR

Section 68.3, become subject to the Accidental Release

Prevention regulations in 40 CFR Part 68, then the owner

or operator shall submit [40 CFR 68.215(a)(2)(i) and

(ii)]:

a. A compliance schedule for meeting the requirements of

40 CFR Part 68 by the date provided in 40 CFR

68.10(a); or

b. A certification statement that the source is in

compliance with all requirements of 40 CFR Part 68,

including the registration and submission of the Risk

Management Plan (RMP), as part of the annual

compliance certification required by 40 CFR Part 70

or 71.

5.2.5 a. Should this stationary source become subject to a

regulation under 40 CFR Parts 60, 61, or 63, or 35 IAC

after the date issued of this permit, then the owner or

operator shall, in accordance with the applicable

regulation(s), comply with the applicable requirements

by the date(s) specified and shall certify compliance

with the applicable requirements of such regulation(s)

as part of the annual compliance certification, as

required by 40 CFR Part 70 or 71.

b. No later than upon the submittal for renewal of this

permit, the owner or operator shall submit, as part

of an application, the necessary information to

address either the non-applicability of, or

demonstrate compliance with all applicable

requirements of any potentially applicable regulation

which was promulgated after the date issued of this

permit.

5.2.6 Episode Action Plan

a. If the source is required to have an episode action

plan pursuant to 35 IAC 244.142, the Permittee shall

maintain at the source and have on file with the

Illinois EPA a written episode action plan (plan) for

reducing the levels of emissions during yellow

alerts, red alerts, and emergencies, consistent with

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safe operating procedures. The plan shall contain

the information specified in 35 IAC 244.144.

b. The Permittee shall immediately implement the

appropriate steps described in this plan should an

air pollution alert or emergency be declared.

c. If a change occurs at the source which requires a

revision of the plan (e.g., operational change,

change in the source contact person), a copy of the

revised plan shall be submitted to the Illinois EPA

for review within 30 days of the change. Such plans

shall be further revised if disapproved by the

Illinois EPA.

d. For sources required to have a plan pursuant to 35

IAC 244.142, a copy of the original plan and any

subsequent revisions shall be sent to:

i. Illinois EPA, Compliance Section; and

ii. For sources located in Cook County and outside

of the city of Chicago: Cook County

Department of Environmental Control; or

iii. For sources located within the city of

Chicago: Chicago Department of Environmental

Control.

5.2.7 CAM Plan

This stationary source has a pollutant-specific emissions

unit that is subject to 40 CFR Part 64, Compliance

Assurance Monitoring (CAM) for Major Stationary Sources.

As a result of this application either not having been

submitted or deemed complete by April 20, 1998, the source

is required to comply with the requirements of 40 CFR Part

64 for large pollutant-specific emissions units in the

initial application and CAAPP permit. The source must

submit a CAM plan for all other affected pollutant-

specific emissions units upon application for renewal of

the initial CAAPP permit, or upon a significant

modification to the CAAPP permit for the construction or

modification of a large pollutant-specific emissions unit

which has the potential post-control device emissions of

the applicable regulated air pollutant that equals or

exceeds major source threshold levels.

5.3 Non-Applicability of Regulations of Concern

None

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5.4 Source-Wide Operational and Production Limits and Work Practices

In addition to the source-wide requirements in the Standard

Permit Conditions in Section 9, the Permittee shall fulfill the

following source-wide operational and production limitations

and/or work practice requirements:

None

5.5 Source-Wide Emission Limitations

5.5.1 Permitted Emissions for Fees

The annual emissions from the source, not considering

insignificant activities as addressed by Section 3.0 of

this permit, shall not exceed the following limitations.

The overall source emissions shall be determined by adding

emissions from all emission units. Compliance with these

limits shall be determined on a calendar year basis.

These limitations (Condition 5.5.1) are set for the

purpose of establishing fees and are not federally

enforceable.

Permitted Emissions of Regulated Pollutants

Pollutant

Tons/Year

Volatile Organic Material (VOM)

230.30

Sulfur Dioxide (SO

2

)

4.34

Particulate Matter (PM)

12.08

Nitrogen Oxides (NO

x

)

35.56

HAP, not included in VOM or PM

----

Total

282.28

5.5.2 Emissions of Hazardous Air Pollutants

This permit is issued based on the emissions of HAPs as

listed in Section 112(b) of the CAA not being equal to or

exceeding 10 tons per year of a single HAP or 25 tons per

year of any combination of such HAPs, so that this source

is considered a minor source for HAPs.

5.5.3 Other Source-Wide Emission Limitations

Other source-wide emission limitations are not set for

this source pursuant to either the federal rules for

Prevention of Significant Deterioration (PSD), 40 CFR

52.21, Illinois EPA rules for Major Stationary Sources

Construction and Modification, 35 IAC Part 203, or Section

502(b)(10) of the CAA. However, there may be unit

specific emission limitations set forth in Section 7 of

this permit pursuant to these rules.

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5.6 General Recordkeeping Requirements

5.6.1 Emission Records

The Permittee shall maintain records of the following

items for the source to demonstrate compliance with

Condition 5.5.1, pursuant to Section 39.5(7)(b) of the

Act:

Total annual emissions on a calendar year basis for

the emission units covered by Section 7 (Unit

Specific Conditions) of this permit.

5.6.2 Records for Operating Scenarios

N/A

5.6.3 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 deviations of the source with the

permit requirements as follows, pursuant to Section

39.5(7)(f)(ii) of the Act. Reports shall describe the

probable cause of such deviations, and any corrective

actions or preventive measures taken.

5.7.2 Annual Emissions Report

The annual emissions report required pursuant to Condition

9.7 shall contain emissions information for the previous

calendar year.

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5.7.3 Annual Reporting of HAP Emissions

The Permittee shall submit an annual report to the

Illinois EPA, Compliance Section, on HAP emissions from

the source, including the following information, so as to

demonstrate whether the source is being operated as a non-

major source of HAP emissions. This report shall be

submitted with the Annual Emissions Report (Condition

9.7).

a. The annual emissions of individual HAPs for each

month of the previous calendar year sufficient to

demonstrate compliance with the 12 month running

total of Condition 5.5.2, tons/year, (e.g., for the

month of January, the emissions from February of the

preceding calendar year through January; for the

month of February, the emissions from March of the

preceding calendar year through February; 12 months

in all); and

b. The total annual emissions of all HAPs combined for

each month of the previous calendar year sufficient

to demonstrate compliance with the 12 month running

total of Condition 5.5.2, tons/year, (e.g., for the

month of January, the emissions from February of the

preceding calendar year through January; for the

month of February, the emissions from March of the

preceding calendar year through February; 12 months

in all).

5.8 General Operational Flexibility/Anticipated Operating Scenarios

N/A

5.9 General Compliance Procedures

5.9.1 General Procedures for Calculating Emissions

Compliance with the source-wide emission limits specified

in Condition 5.5 shall be based on the recordkeeping and

reporting requirements of Conditions 5.6 and 5.7, and

compliance procedures in Section 7 (Unit Specific

Conditions) of this permit.

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6.0 NOT APPLICABLE TO THIS PERMIT

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7.0 UNIT SPECIFIC CONDITIONS

7.1 Unit 01: Vapor Control System

Control: Thermal Treatment Unit (Enclosed Flare)

7.1.1 Description

Operation of a vapor control system that captures and

removes hydrocarbon vapors from the vadose zone (below

ground surface). The vapor control system consists of

control boreholes, a knock out drum, vacuum blowers (75

hp/electric), and an enclosed flare (thermal treatment

unit). All vapors from the vapor control system are

routed to and through the thermal treatment unit.

7.1.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Vapor Control

System

Control Boreholes,

Knock Out Drum,

Vacuum Blowers

(75 Hp/Electric)

1/92

Thermal

Treatment

Unit

(Enclosed

Flare)

7.1.3 Applicability Provisions and Applicable Regulations

a. An “affected vapor control system” for the purpose of

these unit-specific conditions, is the vapor control

system described in Conditions 7.1.1 and 7.1.2.

b. i. 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

219.301].

ii. Emissions of organic material in excess of

those permitted by Condition 7.1.3(c)(i) are

allowable if such emissions are controlled by

a flame or thermal incineration (oxidizer) so

as to either reduce such emissions to 10 ppm

equivalent methane or less, or to convert 85

percent of the hydrocarbons to carbon dioxide

and water [35 IAC 219.302(a)].

7.1.4 Non-Applicability of Regulations of Concern

None

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7.1.5 Operational and Production Limits and Work Practices

a. The thermal treatment unit shall be operated in a

smokeless condition.

b. The thermal treatment unit shall be in operation at

all times when the affected vapor recovery system is

in operation and emitting air contaminants that would

not comply with Condition 7.1.3 without the use of

the thermal treatment unit.

c. The thermal treatment unit combustion chamber shall

be preheated to at least the manufacturer’s

recommended temperature but no less than the

temperature at which compliance was demonstrated in

the most recent compliance test, or 1400

°

F in the

absence of a compliance test. This temperature shall

be maintained during operation

7.1.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, emissions from the

flare shall not exceed the following:

Emissions

Pollutant

(Lb/Hr)

(T/Yr)

VOM

3.78

16.6

CO

10.00

43.8

NO

x

1.84

8.0

PM

10

1.83

8.0

SO

2

0.93

4.1

The above limitations were established in Permit 92050052,

pursuant to Title I of the Clean Air Act, specifically 35

IAC Part 203, Major Stationary Sources Construction and

modification and 40 CFR 52.21, Prevention of Significant

Deterioration (PSD). These limits ensure that the

construction and/or modification addressed in the

aforementioned permit do not constitute a new major source

or major modification pursuant to these rules [T1].

The limits are based on standard emission factors (AP-42),

the heat input rate in condition 7.1.7(b), and 8760

hours/yr of operation. Compliance with annual limits

shall be determined from a running total of 12 months of

data [T1].

7.1.7 Operating Requirements

a. The thermal treatment unit shall be equipped with a

sensor to detect the presence of a flame [T1].

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b. Total heat input to the thermal treatment unit,

including thermal treatment unit gas and contaminated

air shall not exceed 27 mmBtu/hr [T1].

c. Hydrogen Sulfide in the inlet to the thermal

treatment unit shall not exceed 60 ppm [T1].

d. The capture system and thermal treatment unit shall

be operated to reduce VOM emissions by 85% so as to

comply with Condition 7.1.3(c) and (d).

e. Flowrate of contaminated air to the thermal treatment

unit and hydrocarbons in the air shall not exceed

1600 SCFM and 1200 lb/hr [T1].

7.1.8 Monitoring Requirements

The thermal treatment unit shall be equipped with a sensor

to detect the presence of a flame [T1].

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 vapor control system to demonstrate

compliance with Conditions 5.5.1, 7.1.3, 7.1.5, 7.1.7, and

7.1.8, pursuant to Section 39.5(7)(b) of the Act:

a. Thermal oxidizer combustion chamber temperature

(continuous);

b. VOM and HAP emissions (lb/month); and

c. Record of time periods when the flare flame is

extinguished.

7.1.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected

vapor control system 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.

b. The Permittee shall submit an annual report of

emissions listed in Condition 7.1.6 with supporting

calculations. The report shall include a summary of

time periods when the thermal treatment unit flame

was extinguished.

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c. The Illinois EPA shall be notified of permanent

shutdown of the system. Notifications shall be sent

to the Illinois EPA’s Regional office in Collinsville

(see Condition 8.6.4(ii)).

7.1.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.1.12 Compliance Procedures

Compliance with the requirements of Condition 7.1.3(c) and

(d) (35 IAC 219.141 and 219.302) is assured by compliance

with the operational requirements of Condition 7.1.5, the

monitoring requirements of Condition 7.1.8 and the

recordkeeping requirements in Condition 7.1.9.

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7.2 Unit 02: River Dock (Marine Vessel Loading)

Control: Vapor Recovery Unit (for Low-Vapor Pressure Materials)

and Flare (for High-Vapor Pressure Materials)

7.2.1 Description

The marine vessel loading terminal (river dock) delivers

high-vapor pressure materials (e.g. gasoline products,

naphtha, and rerun materials) and low-vapor pressure

materials to marine vessels that operate along the

Mississippi River. The river dock consists of two (2)

loading berths, and can deliver product to a barge vessel

at each of the berths simultaneously.

The loading apparatus is equipped with a vapor recovery

hose positioned at the marine vessel loading positions for

hook up to the flare. The vapor hose and associated

piping transports the hydrocarbon-enriched air displaced

from the marine vessels during loading to a liquid seal

knockout vessel and then to the flare.

7.2.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Date

Modified

Emission Control

Equipment

Unit 02 Marine Vessel Loading 1981* Vapor Recovery

Unit and Flare

* Refurbished in 1981. A new platform was constructed,

a new pipeline was installed to the river dock. The

loading berth was reconditioned and all new piping

and loading arms installed.

7.2.3 Applicability Provisions and Applicable Regulations

a. The “affected marine vessel loading operation” for

the purpose of these unit-specific conditions, is the

operation as described in Conditions 7.2.1 and 7.2.2.

b. The affected marine vessel loading operation is

subject to 35 IAC Part 219, Subpart GG: Marine

Terminals since the source is engaged in delivering

high-vapor pressure materials to marine vessels.

7.2.4 Non-Applicability of Regulations of Concern

a. The affected marine vessel loading operation is not

subject to 35 IAC 219.122, which requires a submerged

loading pipe when loading a volatile organic liquid

(VOL) with a vapor pressure greater than 2.5 psia,

because the rule is only relevant to loading

operations for railroad tank car, tank truck,

trailer, or stationary tank; the affected marine

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vessel loading operation is only engaged in the

loading of marine vessels.

b. The affected marine vessel loading not subject to 35

Ill. Adm. Code 219.120, Control Requirements for

Storage Containers of VOL per 35 Ill. Adm. Code

219.119, which states that limitations of 35 Ill.

Adm. Code 219.120 do not apply to vessels permanently

attached to trucks, railcars, barges, or ships [35

Ill. Adm. Code 219.119(d)].

c. The affected marine vessel loading are not subject to

40 CFR 60, Subpart XX, Standards of Performance for

Bulk Gasoline Terminals, since the affected marine

vessel loading does not deliver liquid product into

gasoline tank trucks as required for applicability.

d. The affected marine vessel loading operations are not

subject to 40 CFR 63, Subpart Y, National Emission

Standards for Marine Tank Vessel Tank Loading

Operations, since the facility has opted to accept a

limit for total loading of high-vapor pressure

materials to marine vessels to no greater than 9.5

million barrels per year; the rule requires 10

million barrels or 200 million barrels per year for

applicability.

7.2.5 Control Requirements and Operational Limitations

a. The affected marine vessel loading operations shall

utilize vapor collection and control system to

control VOM emissions from the marine terminal while

loading gasoline and crude oil, so as to comply with

35 Ill. Adm. Code Part 219 Subpart GG.

b. Pursuant to 35 Ill. Adm. Code 219.762(a), this vapor

collection and control system shall meet the

following requirements:

i. Capture the vapors displaced during the

loading event and reduce overall VOM emissions

by at least 95% by weight through the flare

[35 Ill. Adm. Code 219.762(a)(1)].

ii. Be maintained and operated so that it prevents

visible liquid leaks, significant odors, and

visible fumes in the liquid transfer and the

vapor collection lines, and appurtenances

during loading [35 Ill. Adm. Code

219.762(a)(2)].

iii. Be certified as required by Coast Guard

regulations found at 33 CFR 154 [35 Ill. Adm.

Code 219.762(a)(3)].

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c. Pursuant to 35 Ill. Adm. Code 219.762(b), during the

regulatory control period, gasoline or crude oil

shall only be loaded into marine vessels that are:

i. Equipped with vapor collection equipment that

has been certified as required by Coast Guard

regulations found at 46 CFR 39 [35 Ill. Adm.

Code 219.762(b)(1)].

ii. Connected to the vapor collection system [35

Ill. Adm. Code 219.762(b)(2)]

iii. Vapor-tight as described in 35 Ill. Adm. Code

219.762(b)(3)(A), (b)(3)(B), (b)(3)(C), or

(b)(3)(D) [35 Ill. Adm. Code 219.762(b)(3)].

d. Total loading of high vapor pressure materials to

marine vessels is limited to no greater than 9.5

million barrels per year.

7.2.6 Emission Limitations

There are no specific emission limitations for this unit,

however, there are source wide limitations in Condition

5.5 that include this unit.

7.2.7 Testing and Monitoring Requirements

a. Pursuant to 35 Ill. Adm. Code 219.766, the Permittee

shall comply with the requirements regarding

detection and repair of leaks of 35 Ill. Adm. Code

219.445 for all equipment associated with the vapor

collection and control system, including (see Section

7.7 for further details):

i. Develop a monitoring program plan consistent

with the provisions of 35 Ill. Adm. Code

219.446;

ii. Conduct a monitoring program consistent with

the provisions of 35 Ill. Adm. Code 219.447;

iii. Record all leaking components which have a

volatile organic material concentration

exceeding 10,000 ppm consistent with the

provisions of 35 Ill. Adm. Code 219.448;

iv. Identify each component consistent with the

monitoring program plan submitted pursuant to

35 Ill. Adm. Code 219.446;

v. Repair and retest the leaking components as

soon as possible within 22 days after the leak

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is found, but no later than June 1 for the

purposes of 35 Ill. Adm. Code 219.447(a)(1),

unless the leaking components cannot be

repaired until the unit is shut down for

turnaround; and

vi. Report to the Illinois EPA consistent with the

provisions of 35 Ill. Adm. Code 219.449.

b. Compliance with 35 IAC Section 219.762(a)(2) of this

Subpart shall be determined by visual inspection and

by the leak detection methods contained in Section

219.105(g) of this Part.

c. If the control device used to comply with 35 IAC

Section 219.762(a)(1) of this Subpart is a flare,

compliance shall be determined by methods described

in 35 IAC Section 219.429(c).

d. Compliance with 35 IAC Section 219.762(b)(3) of this

Subpart shall be determined by one of the methods

described in this Section:

i. A marine vessel loaded in accordance with 35

IAC Section 219.762(b)(3)(A) of this Subpart

through the use of a vacuum assisted vapor

collection system is assumed to be vapor-tight

for the purposes of this Subpart.

ii. A vapor-tightness test for marine vessels

shall be conducted to include the final 20

percent of loading of each product tank of the

marine vessel, and it shall be applied to any

potential sources of vapor leaks on the vessel

pursuant to Method 21 of 40 CFR 60, Appendix

A, incorporated by reference at 35 IAC Section

219.112 of this Part. A reading of 10,000

ppmv or greater as methane shall constitute a

leak.

iii. As an alternative to subsection (d)(2) of this

Section, an owner or operator of a marine

terminal may use the vapor-tightness test

described in 40 CFR 61.304(f), incorporated by

reference at 35 IAC Section 219.112 of this

Part.

f. When in the opinion of the Agency or USEPA it is

necessary to conduct testing to demonstrate

compliance with or verify effectiveness of the vapor

collection and control system required by 35 IAC

Section 219.762(a), (c)(1), or (c)(3) of this

Subpart, the owner or operator of a marine terminal

shall, at its own expense, conduct such tests in

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accordance with the applicable test methods and

procedures specified in subsections (a), (b), or (c)

of this Section, as applicable.

g. An owner or operator of a marine terminal planning to

conduct a VOM emissions test to demonstrate

compliance with 35 IAC Sections 219.762(a), (c)(1),

or (c)(3) of this Subpart shall notify the Agency of

that intent not less than 30 days before the planned

initiation of the tests so that the Agency may

observe the test

7.2.8 Inspection and Monitoring Requirements

None

7.2.9 Recordkeeping Requirements

a. General Recordkeeping

The Permittee shall maintain records of the following

for each affected marine vessel loading operations to

demonstrate compliance with Conditions 5.5.1, 7.2.3,

and 7.2.6:

i. The identification and properties of each

organic liquid distributed through each

affected loading rack, as related to emissions,

i.e., vapor pressure and molecular weight;

ii. The amount of each organic liquid distributed

through each affected loading rack, gallons

per month and gallons per year, with annual

records updated each month by totaling the

throughput for that month plus the preceding

11 months;

iii. The number of components (i.e., valves, pump

seals, etc.) in light liquid, heavy liquid or

gas service, as applicable;

iv. Emissions of VOM attributable to loading of

petroleum products, tons/month and tons/year,

with supporting calculations, calculated

utilizing an approved USEPA methodology, such

as Section 5.2 of the AP-42 and the control

efficiency of a VRU as demonstrated in the

most recent test, with annual records updated

each month by totaling the throughput for that

month plus the preceding 11 months (See

Condition 7.1.12(c) for gasoline loading); and

v. Emissions of VOM attributable to fugitive

losses (valves, pump seals, etc.), tons/month

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and tons/year, with supporting calculations,

calculated utilizing an approved USEPA

methodology.

b. The owner or operator of sources complying with 35

IAC Sections 219.762(a) and (b), or (c)(1), or (c)(3)

of this Subpart shall maintain records regarding the

marine terminal, and each time a marine vessel is

loaded during the regulatory control period. The

records shall include but are not limited to:

i. The date(s) and the time(s) at which the

marine vessel was loaded from the marine

terminal;

ii. The name, type, identification number, and

owner of the vessel loaded;

iii. The type and amount of liquid loaded into the

marine vessel;

iv. Records of any leaks found, repair attempts,

and the results of the required fugitive

monitoring and maintenance program, including

appropriate dates, test methods, instrument

readings, repair results, and corrective

action taken as required by 35 IAC Sections

219.762(a)(2) and 219.766 of this Subpart;

v. A copy of the Coast Guard certification

demonstrating that the marine terminal's vapor

collection and control system has been

certified as required by Coast Guard

regulations found at 33 CFR 154; and

vi. A copy of the Coast Guard certification

demonstrating that the marine vessel has been

inspected and certified as required by Coast

Guard regulations found at 46 CFR 39. If a

copy of the Coast Guard certificate is not

available at the time of loading, then the

date that the marine vessel was last inspected

and the authorization that the marine vessel

has functioning vapor control equipment must

be recorded from the certificate. Further, a

copy of the certificate must be obtained by

the owner or operator of the marine terminal

within 21 days after the loading event.

c. Owners or operators complying with 35 IAC Sections

219.762(b)(3)(B), (b)(3)(C), or (b)(3)(D) shall

additionally maintain the following records

concerning the vapor-tightness of the marine vessel:

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i. Test title;

ii. Owner of the marine vessel tested;

iii. The identification number of the marine vessel

tested;

iv. Testing location;

v. Tester name and signature;

vi. Witnessing inspector, name, signature, and

affiliation; and

vii. Test results.

d. Owners or operators complying with the requirements

of 35 IAC Section 219.762(c)(2) of this Subpart shall

maintain records of daily product volumes loaded to

demonstrate that the applicable emission reduction

specified in Appendix E of this Part has been

achieved.

e. Owners or operators certifying compliance under 35

IAC Section 219.764(c) shall maintain the records

specified in subsections (b)(1), (b)(2), and (b)(3)

above.

f. All records required by subsections (b), (c), (d),

and (e) of this Section shall be maintained for at

least three years and shall be made available to the

Agency upon request.

g. Total natural gas usage for flare (ft

3

/mo)

7.2.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected marine

vessel loading operations 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.

7.2.11 Operational Flexibility/Anticipated Operating Scenarios

The Permittee is authorized to make the following physical

or operational change with respect to an affected loading

rack 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

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constituting construction or modification of the source,

as defined in 35 IAC 201.102:

None

7.2.12 Compliance Procedures

a. Compliance with the operational limitations of

Condition 7.2.5(a), shall be demonstrated through the

inspection/monitoring, recordkeeping and reporting

requirements of Conditions 7.2.8, 7.2.9, and 7.2.10

and the compliance procedures in 7.2.12(c) and (d).

b. Compliance with the control requirements of 7.2.5(a)

shall be demonstrated by the inspection/monitoring,

recordkeeping and reporting requirements of

Conditions 7.2.8, 7.2.9, and 7.2.10 and the fact that

compliance of loading rack and associated vapor

recovery unit have previously been demonstrated by

fulfillment of the test requirements of 40 CFR 60.8

by measurement of the total organic concentration(s)

in the effluent stream of the vapor recovery system

pursuant to 40 CFR 60.503.

c. VOM and HAP emission from the loading shall be

calculated by use of the following equations:

i. Total VOM Emissions (lb) = Throughput

(gallons) x EF

*

X (1 – Control Efficiency of

Flare/100)

Where:

Throughput = Loading Rack Throughput as

Determined by the Records Required in 7.2.9(a)

Control Efficiency of Flare = 97 %

* Emission Factors as provided in the Title

5 application

ii. HAP emissions = VOM emissions X EF

**

Material Loaded

Emission Factor

lb/1000 Gallon

Gasoline

3.90

Distillate Fuel Oil

0.012

** Emission Factors as provided in the Title

5 application

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HAP

HAP to VOM

Emission

Factor (%

by Wt.) for

Gasoline

HAP to VOM

Emission Factor

(% by Wt.) for

Distillate Fuel

Oil No. 2

Benzene

0.53

12.38

Cumene

0.02

0.37

Ethylbenzene

0.06

0.38

Hexane

4.43

24.76

Toluene

0.84

4.36

Xylene

0.24

2.45

2,2,4-Trimethylpentane

0.99

0.28

d. Emissions from the flare burning natural gas shall be

calculated based on the following emission factors:

Pollutant

Emission Factor

(Lb/mmBtu)

NO

x

1

0.068

PM/PM

10

2, 3

7.6

SO

2

2,3

0.6

CO

1

0.37

1

Emissions calculated using emission factors

from AP-42, Table 13.5-1, Emission Factors for

Flare Operations.

2

These are the emission factors for

uncontrolled natural gas combustion in

commercial boilers (< 100 mmBtu/hr), Table

1.4-2, AP-42, Volume I, Supplement D, July

1998. VOM emission factor based on TOC factor

corrected for 52% methane contribution.

3

Emissions calculated assuming that natural gas

and gasoline have similar quantities of PM and

SO

2

resulting from combustion

Flare Emissions (Ton) = Natural Gas Consumed

Multiplied by the Appropriate Emission

Factor/2,000.

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7.3 Unit 03: External Floating Roof Storage Tanks

Control: Floating Roof, Double Seals and Submerged Loading

7.3.1 Description

The terminal has a number of storage tanks used to store

gasoline (RVP 15), ethanol, and all VPLs with vapor

pressure lower than gasoline.

7.3.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Unit 03 External Floating

Roof Tanks:

120-1

120-2

120-3

120-4

102-5

120-7

120-8

120-10

120-11

80-4

80-5

80-10

80-11

20-8

10-20

5-10

1947

1947

1953

1953

1953

1957

1945

1949

1953

1953

1960

1961

1954

Floating Roof,

Primary Seal

and Rim-Mounted

Secondary Seal,

Submerged

Loading

7.3.3 Applicability Provisions

a. An “affected tank,” for the purposes of these unit-

specific conditions, is a storage tank that is only

subject to the requirements of 35 IAC 219.121,

219.122(b), 219.123, and 219.124. Each storage tank

with a capacity of 151.42 cubic meters (approx.

40,000 gallons) or more, storing volatile petroleum

liquid (VPL), equipped with an external floating roof

is subject to the requirements of 35 IAC 219.124(a)

unless it is exempted pursuant to 35 IAC 219.124(b).

A tank also may be exempt due to the current service,

features, or other circumstances associated with the

tank. A tank must comply with other rules if the

vapor pressure of the VPL is 86.19 kPa (12.5 psia) or

greater at 294.3°K (70°F).

As of the “date issued” as shown on page 1 of this

permit, the affected tanks are identified in

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Condition 7.3.2. The status of all storage tanks at

this source, including affected tanks that are

subject to 35 IAC 218.124(a), is summarized in

Attachment 1.

b. When storing a volatile organic liquid (VOL, e.g.

ethanol), each tank is subject to 35 IAC

219.120(a)(3) which requires double seals.

Compliance with Condition 7.3.5, 7.3.7 and 7.3.8

shall be deemed compliance with this requirement.

7.3.4 Non-Applicable Regulations

None

7.3.5 Control Requirements

Each affected tank shall be equipped with the following:

a. A floating roof which rests on the surface of the VOL

that is equipped with a primary seal [35 IAC

219.121(b)(1)];

b. A floating roof that is equipped with a continuous

seal extending from the floating roof to the tank

wall (rim mounted secondary seal) [35 IAC

219.124(a)(1)] (The Illinois EPA has not approved

use of other equivalent equipment in lieu of a rim-

mounted secondary seal.);

c. All drains (for drainage of rainwater, also know as

“stub drains”) in the floating roof deck shall be

provided with slotted membrane fabric covers or

equivalent covers across at least 90 percent of the

area of the opening [35 IAC 219.124(a)(3)];

d. All openings of the floating roof deck, other than

drains, shall be equipped with projections into the

tank which remain below the liquid surface at all

times except when supported on the roof legs and be

equipped with covers, lids or seals [35 IAC

219.124(a)(4)]; and

e. A permanent submerged loading pipe [35 IAC

219.122(b)].

7.3.6 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.

None

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7.3.7 Operating Requirements

a. Each affected tank shall be operated so that the

floating roof including the seal closure devices meet

the following requirements:

i. There shall be no visible holes, tears, or

other defects in the seal or any seal fabric

or material of the floating roof [35 IAC

219.123(b)(2)];

ii. The seal is intact and uniformly in place

around the circumference of the floating roof

between the floating roof and tank wall [35

IAC 219.124(a)(2)(A)];

iii. The accumulated area of gaps exceeding 0.32

centimeter (1/8 inch) in width between the

secondary seal and the tank wall shall not

exceed 21.2 square centimeters per meter of

tank diameter (1.0 square inch per foot of

tank diameter) [35 IAC 219.124(a)(2)(B)]; and

iv. The covers, lids or seals on openings of the

floating roof deck other than stub drains

shall be operated such that the following

requirements are met:

A. The cover, lid or seal is in the closed

position at all times except when

petroleum liquid is transferred to or

from the tank [35 IAC 219.123(b)(3)(A)];

B. Automatic bleeder vents are closed at all

times except when the roof is floated off

or landed on the roof leg supports [35

IAC 219.123(b)(3)(B)]; and

C. Rim vents, if provided, are set to open

when the roof is being floated off the

roof leg supports or at the

manufacturer’s recommended setting [35

IAC 219.123(b)(3)(C)].

b. No person shall cause or allow the emissions of air

contaminants into the atmosphere from any gauging or

sampling devices attached to an affected tank, except

during sampling or maintenance operations [35 IAC

219.121 (b)(1)].

7.3.8 Inspection Requirements

a. The Permittee shall inspect each affected tank prior

to May 1 of each year, to insure compliance with the

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applicable control and operating requirements [35

IAC 219.124(a)(5)].

b. i. The Permittee shall measure the secondary seal

gap of each affected tank prior to May 1 of

each year. This measurement shall be

conducted in accordance with the methods and

procedures specified in 40 CFR 60, Subpart Kb

[35 IAC 219.124(a)(6)].

ii. Prior notification for the above measurements

shall be given to the Illinois EPA as

specified in Condition 7.3.10(b).

c. The Permittee shall perform a complete inspection of

the cover and seals of each affected tank whenever

the tank is emptied and degassed for any reasons

other than the transfer of liquid during the normal

operation of the tank, or whenever repairs are made

that require degassing of the tank as a result of any

semi-annual inspection or incidence of roof damage or

defect [35 IAC 219.123(b)(5)].

7.3.9 Recordkeeping Requirements

a. In addition to the records required by Condition 5.6

(requiring records of throughput and emissions), the

Permittee shall maintain records of the following

items for each affected tank, pursuant to 35 IAC

219.123(b)(6) and 219.124(a)(7):

i. A list of the types of volatile petroleum

liquid stored on a monthly basis;

ii. The maximum true vapor pressure of each type

of liquid as stored, psia;

iii. The results of any inspections or measurements

required by the Condition 7.3.8(a), (b) and/or

(c), including:

A. Type of inspection;

B. When the inspection and/or measurement

was performed;

C. Who performed the inspection and/or

measurement;

D. The method of inspection and/or

measurement;

E. The observed condition of each feature of

the external floating roof (seals, roof

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deck and fittings) with raw data recorded

during the inspection and/or measurement;

and

F. Summary of compliance.

b. The Permittee shall maintain records of the following

for each affected tank to demonstrate compliance with

Condition 7.3.8(c) (Cover and Seal Inspection) [35

IAC 219.123(b)(6)]:

Records that are sufficient to identify

whenever the tank is emptied and degassed for

any reason other than the transfer of liquid

during normal operation or whenever repairs

are made as a result of regular inspections or

incident of roof damage or defect.

7.3.10 Reporting Requirements

a. The Permittee shall notify the Illinois EPA,

Compliance Section and Regional Field Office, at

least 30 days before the planned performance of seal

gap measurements, pursuant to Section 39.5(7)(f) of

the Act, so the Illinois EPA may observe the

measurements.

b. The Permittee shall promptly notify the Illinois EPA,

Compliance Section of deviations with the control,

operating, or inspection requirements, as follows

pursuant to Section 39.5(7)(f)(ii) of the Act:

i. Any storage of VPL in an affected tank that is

not in compliance with the control

requirements (due to absence of the features

required by Condition 7.3.5, e.g., “no rim-

mounted secondary seal,”) within 5 days of

becoming aware of the non-compliance status.

This notification shall include a description

of the event, the cause for the non-

compliance, actions taken to correct the non-

compliance, and the steps to be taken to avoid

future non-compliance.

ii. Any storage of VPL in an affected tank that is

out of compliance with the control

requirements (Condition 7.3.5) due to damage,

deterioration, or other condition of the tank,

within 30 days of becoming aware of the non-

compliance status. This notification shall

include a description of the event, the cause

for the non-compliance, actions taken to

correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

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7.3.11 Operational Flexibility/Anticipated Operating Scenarios

The Permittee is authorized to make the following physical

or operational change with respect to an affected tank

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:

a. Changes in the material stored in a tank, provided

the tank continues to comply with the Conditions in

Section 7.3 of this permit.

b. The primary seals may be replaced with the same or a

different type. Secondary seals may be replaced but

must be rim-mounted.

7.3.12 Compliance Procedures

a. Emissions from each affected storage tank shall be

determined through the use of the TANKS program,

AP-42 upon which the Tanks Program is based, or any

other method that utilizes USEPA approved emission

factors for storage tank emissions.

b. For the purpose of estimating HAP emissions from

equipment at the facility, the vapor wt percent

(based on a 1992 USEPA survey or calculations based

upon the applicable MSDS for the specific VOL) of

each HAP for each product times the VOM emissions

contributed by that product is acceptable. Other

means of estimating HAP emissions utilizing USEPA

accepted methodologies is also acceptable.

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7.4 Unit 04: Internal Floating Roof Storage Tanks

Control: Floating Roof and Seals, Permanent Submerged Loading

7.4.1 Description

The Permittee operates a six (6) internal floating roof

storage tanks to store gasoline (RVP 15), ethanol, and all

VPLs with vapor pressure lower than gasoline. Permanent

submerged loading is an inherent part of this design since

there is no vapor space.

7.4.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed/

Modified

Emission

Control

Equipment

Group 1 Tanks*:

20-3/840,000 Gal

10-10/420,000 Gal

1948/1990

1941/1994

Group 2 Tanks (Not

Subject to NSPS):

10-5/420,000 Gal

10-7/420,000 Gal

T-3-1/ 126,000 Gal

1941

1941

1956

Unit 04

Group 3 Tank**

120-9/5,040,000 Gal

1975

Internal

Floating Roof,

Submerged

Loading

* Subject to 40 CFR 60, Subpart Kb

** subject to 40 CFR 60, Subpart K

7.4.3 Applicability Provisions and Applicable Regulations

a. The affected tanks, for the purpose of these unit

specific conditions, are the tanks as described in

Conditions 7.4.1 and 7.4.2.

b. An “affected tank” of group 1, for the purposes of

these unit specific conditions, are the storage tanks

that are subject to the control requirement of 40 CFR

60 Subpart Kb (Standards of Performance for Volatile

Organic Liquid Storage Vessels (Including Petroleum

Liquid Storage Vessels) for Which Construction,

Reconstruction, or Modification Commenced After

July 23, 1984); these tanks rely on an internal

floating roof for compliance. A storage tank

constructed, reconstructed, or modified after

July 23, 1984 is subject to the control requirements

of 40 CFR 60 Subpart Kb if it has a capacity greater

than or equal to 20,000 gallons (75 m

3

) storing a VOL

with a maximum true vapor pressure of 15 kPa (2.2

psia) or more or a capacity greater than or equal to

40,000 gallons (151 m

3

) storing a VOL with a maximum

true vapor pressure of 3.5 kPa (0.5 psia) or more.

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As of the “date issued” as shown on page 1 of this

permit, the affected tanks are identified in

Condition 7.4.2.

c. Each storage tank subject to 40 CFR 60 Subpart Kb is

hereby shielded from compliance with 35 IAC 219.121.

This shield is issued to streamline the applicable

requirements for the source, based on the Illinois

EPA’s finding that compliance with 40 CFR 60, Subpart

Kb assures compliance with 35 IAC 219.121, following

the review requirements of 40 CFR 60 Subpart Kb and

35 IAC 219.121.

d. The “affected tanks” of group 2, for the purposes of

these unit-specific conditions, are the storage tanks

that are subject to the requirements of 35 IAC

219.121, 219.122(b), and 219.123. Each storage tank

with a capacity of 151.42 cubic meters (approx.

40,000 gallons) or more, storing volatile petroleum

liquid (VPL), is subject to the requirements of 35

IAC 219.123(b) unless it is specifically excluded

pursuant to 35 IAC 219.123(a). Group 1 and 2 tanks

are exempt from some of the requirements based on

applicability of a NSPS [35 IAC 219.123(a)(5)]. A

tank also may be exempt due to the current service,

features, or other circumstances associated with the

tank (See Condition 5.8). A tank must comply with

other rules if the vapor pressure of the VPL is 86.19

kPa (12.5 psia) or greater at 294.3

°

K (70

°

F).

When in VOL service (e.g., storing ethanol), an

“affected tank,” for the purposes of these

unit-specific conditions, is a storage tank subject

to the requirements of 35 IAC 219.120(a) and

219.122(b) that relies upon a permanent submerged

loading pipe and internal floating roof for

compliance. An affected storage tank is subject to

the control requirements of 35 IAC 219.120(a) if it

has a capacity greater than or equal to 40,000

gallons storing a VOL with a vapor pressure of 0.75

psia or more but less than or equal to a maximum true

vapor pressure of 11.1 psia [35 IAC 219.120(a)(1)].

As of the “date issued” as shown on page 1 of this

permit, the affected tanks are identified in

Condition 7.4.2.

e. Tank 120-9 is subject to the control requirement of 40

CFR 60 Subpart K (Standards of Performance for Storage

Vessels for Petroleum Liquids for Which Construction,

Reconstruction, or Modification Commenced After

June 11, 1973, and Prior to May 19, 1978) and relies

on an internal floating roof for compliance. A

storage tank constructed, reconstructed, or modified

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after March 8, 1974, and prior to May 19, 1978 is

subject to the control requirements of 40 CFR 60

Subpart K that has a capacity greater than 151, 416

liters (40,000 gallons), but not exceeding 246,052

liters (65,000 gallons); alternatively, a storage tank

may be subject to 40 CFR 60 Subpart K if it has a

capacity greater than 246,052 liters (65,000 gallons)

and commences construction or modification after

June 11, 1973, and prior to May 19, 1978.

f. Each affected tank is subject to the emission limits

identified in Condition 5.2.2.

7.4.4 Non-Applicability of Regulations of Concern

a. Groups 1 tanks and 120-9 tank are not subject to 35

IAC 219.123 when in VPL service because they are

subject to a NSPS [35 IAC 219.123(a)(5)]. Though

these tanks are subject to 35 IAC 219.121, compliance

with Subpart Ka or Kb is deemed to be more stringent

and will demonstrate compliance with 35 IAC 219.121.

c. The affected tanks are not subject to 35 IAC 219.124

because the tanks are considered internal floating

roof tanks.

d. This permit is issued based on the affected storage

tanks not being subject to 40 CFR Part 64, Compliance

Assurance Monitoring (CAM) for Major Stationary

Sources, because the affected storage tanks uses a

passive control measure, such as a seal, lid, or

roof, that is not considered a control device because

it acts to prevent the release of pollutants.

7.4.5 Control Requirements and Work Practices

a. Each affected tank of Group 1 and tank 120-9 shall

comply with the requirements of 40 CFR

60.112b(a)(1)(i) and 40 CFR 60.112(a)(1),

respectively, which requires the use of a floating

roof that is equipped with one of the following

closure devices:

i. A foam-filled or liquid-filled liquid-mounted

seal; or

ii. Two continuous seals; or

iii. A mechanical shoe seal

b. Each affected tanks shall also be equipped with a

permanent submerged loading pipe, pursuant to 35 IAC

219.122(b).

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c. When storing a VPL with a vapor pressure of 1.5 psia

or greater and VOL with a vapor pressure of 1.5 psia

or greater storage tanks of group 1 and tank 120-9

shall be equipped with a floating roof which rests on

the surface of the VOL that is equipped with a

primary seal [35 IAC 219.121(b)(1) and 40 CFR

60.112a(a)(2)];

d. For storage tanks of group 1 and tank 120-9 all

openings of the floating roof deck, other than

drains, shall be equipped with covers, lids or seals

[35 IAC 219.123(b)(3)]; and

e. When any tank is in ethanol (VOL) service the

following control requirements apply:

i. An internal floating roof which shall rest or

float on the liquid surface (but not

necessarily in complete contact with it)

inside a storage vessel that has a fixed roof.

The internal floating roof shall be floating

on the liquid surface at all times, except

during initial fill and during those intervals

when the storage vessel is completely emptied

and subsequently refilled. When the roof is

resting on the leg supports, the process of

filling, emptying, or refilling shall be

continuous and shall be accomplished as

rapidly as possible [35 IAC

219.120(a)(1)(A)].

ii. Each internal floating roof shall be equipped

with one of the following closure devices

between the wall of the storage vessel and the

edge of the internal floating roof [35 IAC

219.120(a)(1)(B)]:

A. A foam- or liquid-filled seal mounted in

contact with the liquid (liquid-mounted

seal). A liquid-mounted seal means a

foam- or liquid-filled seal mounted in

contact with the liquid between the wall

of the storage vessel and the floating

roof continuously around the

circumference of the tank;

B. Two seals mounted one above the other so

that each forms a continuous closure that

completely covers the space between the

wall of the storage vessel and the edge

of the internal floating roof. The lower

seal may be vapor-mounted, but both must

be continuous; or

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C. A mechanical shoe seal, which is a metal

sheet held vertically against the wall of

the storage vessel by springs or weighted

levers and is connected by braces to the

floating roof. A flexible coated fabric

(envelope) spans the annular space

between the metal sheet and the floating

roof.

iii. Each opening in a noncontact internal floating

roof except for automatic bleeder vents

(vacuum breaker vents) and the rim space vents

is to provide a projection below the liquid

surface [35 IAC 219.120(a)(1)(C)].

iv. Each opening in the internal floating roof

except for leg sleeves, automatic bleeder

vents, rim space vents, column wells, ladder

wells, sample wells, and stub drains is to be

equipped with a cover or lid which is to be

maintained in a closed position at all times

(i.e., no visible gap) except when the device

is in actual use. The cover or lid shall be

equipped with a gasket. Covers on each access

hatch and automatic gauge float well shall be

bolted except when they are in use [35 IAC

219.120(a)(1)(D)].

v. Automatic bleeder vents shall be equipped with

a gasket and are to be closed at all times

when the roof is floating except when the roof

is being floated off or is being landed on the

roof leg supports [35 IAC 219.120(a)(1)(E)].

vi. Rim space vents shall be equipped with a

gasket and are to be set to open only when the

internal floating roof is not floating or at

the manufacturer’s recommended setting [35

IAC 219.120(a)(1)(F)].

vii. Each penetration of the internal floating roof

for the purpose of sampling shall be a sample

well. The sample well shall have a slit

fabric cover that covers at least 90 percent

of the opening [35 IAC 219.120(a)(1)(G)].

viii. Each penetration of the internal floating roof

that allows for passage of a ladder shall have

a gasketed sliding cover [35 IAC

219.120(a)(1)(H)].

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7.4.6 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.

None

7.4.7 Operating Requirements

Each affected group 1 tank shall be operated in compliance

with the operating requirements of 40 CFR 60.112b(a)(1)

and 60.113b(a), as follows:

a. The internal floating roof shall float on the liquid

surface at all times, except during those intervals

when the storage tank is being completely emptied and

subsequently refilled and the roof rests on its leg

supports. When the roof is resting on its leg

supports, the process of emptying or refilling shall

be continuous and shall be accomplished as rapidly as

possible. [40 CFR 60.112b(a)(1)(i)].

i. Each opening in a non-contact internal

floating roof except for automatic bleeder

vents (vacuum breaker vents) and the rim space

vents shall provide a projection below the

liquid surface [40 CFR 60.112b(a)(1)(iii)].

ii. Each opening in the internal floating roof

except for leg sleeves, automatic bleeder

vents, rim space vents, column wells, ladder

wells, sample wells, and stub drains shall be

equipped with a cover or lid which is

maintained in a closed position at all times

(i.e., no visible gaps) except when the device

is in actual use. The cover or lid shall be

equipped with a gasket. Covers on each access

hatch and automatic gauge float well shall be

bolted except when they are in use [40 CFR

60.112b(a)(1)(iv)].

iii. Automatic bleeder vents shall be equipped with

a gasket and be closed at all times when the

roof is floating except when the roof is being

floated off or is being landed on the roof leg

supports [40 CFR 60.112b(a)(1)(v)].

iv. Rim space vents shall be equipped with a

gasket and be set to open only when the

internal floating roof is not floating or at

the manufacturer’s recommended setting [40

CFR 60.112b(a)(1)(vi)].

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v. Each penetration of the internal floating roof

for the purpose of sampling shall be a sample

well. The sample well shall have a slit

fabric cover that covers at least 90 percent

of the opening [40 CFR 60.112b(a)(1)(vii)].

vi. Each penetration of the internal floating roof

that allows for the passage of a column

supporting the fixed roof shall have a

flexible fabric sleeve seal or a gasketed

sliding cover [40 CFR 60.112b(a)(1)(viii)].

vii. Each penetration of the internal floating roof

that allows for passage of a ladder shall have

a gasketed sliding cover [40 CFR

60.112b(a)(1)(ix)].

viii. A tank that is in-service shall be repaired or

emptied upon identification in an inspection

that the floating roof is not resting on the

surface of the VOL, there is liquid

accumulated on the roof, the seal is detached,

or there are holes or tears in the seal

fabric. These actions shall be completed

within 45 days of the inspection unless an

extension is granted [40 CFR 60.113b(a)(2)

and (a)(3)(ii)].

ix. A tank that is empty shall be repaired prior

to refilling the tank upon identification in

an inspection that the floating roof has

defects, the primary seal has holes, tears or

other openings in the seal or seal fabric, or

the secondary seal has holes, tears or other

openings in the seal or seal fabric, or the

gaskets no longer close off [40 CFR

60.113b(a)(3)(ii) and (a)(4)].

x. Group 2 storage tanks shall be operated so

that the floating roof including the seal

closure devices meet each of the following

requirements:

A. There shall be no visible holes, tears,

or other defects in the seal or any seal

fabric or material of the floating roof

[35 IAC 219.123(b)(2)];

B. The covers, lids or seals on openings of

the floating roof deck other than stub

drains shall be operated such that the

following requirements are met:

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1. The cover, lid or seal is in the

closed position at all times except

when petroleum liquid is

transferred to or from the tank

[35 IAC 219.123(b)(3)(A)];

2. Automatic bleeder vents are closed

at all times except when the roof

is floated off or landed on the

roof leg supports [35 IAC

219.123(b)(3)(B)]; and

3. Rim vents, if provided, are set to

open when the roof is being floated

off the roof leg supports or at the

manufacturer’s recommended setting

[35 IAC 219.123(b)(3)(C)].

b. No person shall cause or allow the emissions of air

contaminants into the atmosphere from any gauging or

sampling devices attached to an affected Group 1 or

Group 2 tank, except during sampling or maintenance

operations [35 IAC 219.121 (b)(1)].

7.4.8 Inspection Requirements

a. The Permittee shall fulfill the applicable testing

and procedures requirements of 40 CFR 60.113b(a) for

each tank of Group 1 equipped with an internal

floating roof as follows:

i. Visually inspect the internal floating roof

and the primary seal or the secondary seal (if

one is in service) through manholes and roof

hatches on the fixed roof at least once ever

12 months (Annual Inspection) to identify any

deficiency or shortcoming in the roof’s

features, (i.e., the internal floating roof is

not resting on the surface of the VOL inside

the storage tank, or there is liquid

accumulated on the roof, or the seal is

detached, or there are holes or tears in the

seal fabric) that the Permittee must repair or

otherwise remove the storage tank from service

[40 CFR 60.113b(a)(2) and (a)(3)(ii)].

ii. Visually inspect the internal floating roof

the primary seal, the secondary seal (if one

is in service), gaskets, slotted membranes (if

any), and sleeve seals (if any) each time the

storage vessel is emptied and degassed (Out-of

Service Inspection) to identify any deficiency

or shortcoming in the roof’s features, (i.e.,

internal floating roof has defects, the

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primary seal has holes, tears, or other

openings in the seal or the seal fabric, or

the secondary seal has holes, tears, or other

openings in the seal or the seal fabric, or

the gaskets no longer close off the liquid

surfaces from the atmosphere, or the slotted

membrane has more than 10 percent open area)

that the Permittee shall repair the features

prior to refilling the storage tank with VOL.

In no event shall inspections conducted in

accordance with this provision occur at

intervals greater than 10 years in the case of

vessels conducting the annual visual

inspection as specified in 40 CFR

60.113b(a)(2) and (a)(3(ii) and at intervals

no greater than 5 years in the case of vessels

specified in 40 CFR 60.113b(a)(3)(i) [40 CFR

60.113b(a)(3)(i) and (a)(4)].

iii. Prior notification for the above inspection

shall be given to the Illinois EPA as

specified in Condition 7.4.10(a)(ii).

b. The Permittee shall inspect the floating roof seals

of each affected Group 2 tank when storing a VPL with

a vapor pressure of 1.5 psia or greater once every

six months. Compliance will be demonstrated with the

timing of the inspections if two inspections occur

within a calendar year with one taking place in

January through June and the second taking place in

July through December; or if the inspections are not

more than 190 days apart [35 IAC 219.123(b)(4)].

c. The Permittee shall perform a complete inspection of

the cover and seals of each affected Group 2 tank

whenever the tank is emptied and degassed for any

reasons other than the transfer of liquid during the

normal operation of the tank, or whenever repairs are

made that require the tank to be emptied and degassed

as a result of any semi-annual inspection or incidence

of roof damage or defect [35 IAC 219.123(b)(5)].

d. When any tank is in ethanol service (VOL), the

following inspection requirements will apply:

i. Visually inspect the internal floating roof,

the primary seal, and the secondary seal (if

one is in service) prior to filling the

storage vessel with VOL. If there are holes,

tears, or other openings in the primary seal,

the secondary seal, or the seal fabric or

defects in the internal floating roof, or

both, the owner or operator shall repair the

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items before filling the storage vessel [35

IAC 219.127(a)(1)].

ii. For vessels equipped with a liquid-mounted or

mechanical shoe primary seal, visually inspect

the internal floating roof and the primary

seal or the secondary seal (if one is in

service) through manholes and roof hatches on

the fixed roof at least once every 12 months

after initial fill. If the internal floating

roof is not resting on the surface of the VOL

inside the storage vessel, or if there is

liquid accumulated on the roof, or if the seal

is detached, or if there are holes or tears in

the seal fabric, the owner or operator shall

repair the items or empty and remove the

storage vessel from service within 45 days.

If a failure that is detected during

inspections required in this subsection cannot

be repaired within 45 days and if the vessel

cannot be emptied within 45 days, the owner or

operator may request a 30-day extension from

the Illinois EPA in the inspection report

required in 35 IAC 218.129(a)(3). Such a

request for an extension must document that

alternate storage capacity is unavailable and

specify a schedule of actions the owner or

operator will take that will assure that the

control equipment will be repaired or the

vessel will be emptied within 30 days [35 IAC

219.127(a)(2)].

iii. For vessels equipped with both primary and

secondary seals:

A. Visually inspect the vessel as specified

in subsection (iv) below at least every 5

years; or

B. Visually inspect the vessel as specified

in subsection (ii) above.

iv. Visually inspect the internal floating roof,

the primary seal, the secondary seal (if one

is in service), gaskets, slotted membranes,

and sleeve seals (if any) each time the

storage vessel is emptied and degassed. If

the internal floating roof has defects, the

primary seal has holes, tears, or other

openings in the seal, or if the seal fabric or

the secondary seal has holes, tears, or other

openings in the seal, or if the seal fabric or

the gaskets no longer close off the liquid

surfaces from the atmosphere, or if the

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slotted membrane has more than 10 percent open

area, the owner or operator shall repair the

items as necessary so that none of the

conditions specified in this subsection exist

before refilling the storage vessel with VOL.

In no event shall inspections conducted in

accordance with this provision occur at

intervals greater than 10 years in the case of

vessels subject to the annual visual

inspection as specified in subsections (ii)

and (iii)(B) above and at intervals no greater

than 5 years in the case of vessels specified

in subsection (iii)(A) above.

v. Notify the Illinois EPA in writing at least 30

days prior to the filling or refilling of each

storage vessel for which an inspection is

required by subsections (i) and (iv) above to

afford the Illinois EPA the opportunity to

have an observer present. If the inspection

required by subsection (iv) above is not

planned and the owner or operator could not

have known about the inspection 30 days in

advance of refilling the tank, the owner or

operator shall notify the Illinois EPA at

least 7 days prior to the refilling of the

storage vessel. Notification shall be made by

telephone immediately followed by written

documentation demonstrating why the inspection

was unplanned. Alternatively, this

notification including the written

documentation may be made in writing and sent

by express mail so that it is received by the

Illinois EPA at least 7 days prior to the

refilling [35 IAC 219.127(a)(5)].

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 each affected storage tank to demonstrate compliance

with Conditions 5.5.1, 7.4.3, 7.4.5, 7.4.6, 7.4.7, and

7.4.8, pursuant to Section 39.5(7)(b) of the Act:

a. The Permittee shall fulfill the applicable

recordkeeping requirements of 40 CFR 60.115b for each

affected Group 1 tanks pursuant to 40 CFR 60.115b(a),

as follows:

Keep a record of each Annual and Out-of-Service

Inspection performed as required by Condition

7.4.8(a)(i)-(ii) [40 CFR 60.115b(a)(2)].

i. The date the inspection was performed;

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ii. Who performed the inspection;

iii. The method of inspection;

iv. The observed condition of each feature of the

internal floating roof (seals, roof decks and

fittings), with the raw data recorded during

the inspection; and

v. Summary of compliance.

b. The Permittee shall maintain records of the following

for each affected tank to demonstrate compliance with

the Out-of-Service Inspection requirements of

Conditions 7.4.8(a)(ii), 7.4.8(c) and 7.4.8(d)(iv):

Records that are sufficient to identify

whenever the tank is empty for any reason or

whenever repairs are made as a result of

regular inspection or incident of roof damage

or defect.

c. The Permittee shall keep the operating records

required by 40 CFR 60.116b for each affected tanks of

group 1, as follows:

Records of the VOL stored, the period of

storage, and the maximum true vapor pressure

of that VOL during the respective storage

period [40 CFR 60.116b(c)].

d. In addition to the records required by Condition 5.6

(requiring records of throughput and emissions), the

Permittee shall maintain records of the following

items for each affected tank (Group 2) in VPL

service, pursuant to 35 IAC 215.123(b)(6) or 40 CFR

60.113:

i. A list of the types of volatile petroleum

liquid stored on a monthly basis;

ii. The maximum true vapor pressure of each type

of liquid as stored, psia; and

iii. For Group 2 tanks the results of any

inspections or measurements required by the

Condition 7.4.8(a) and/or (b), including:

A. Type of inspection;

B. When the inspection and/or measurement

was performed;

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C. Who performed the inspection and/or

measurement;

D. The method of inspection and/or

measurement;

E. The observed condition of each feature of

the external floating roof (seals, roof

deck and fittings) with raw data recorded

during the inspection and/or measurement;

and

F. Summary of compliance.

e. The Permittee shall maintain records of the following

for each affected Group 2 tank to demonstrate

compliance with Condition 7.4.8(b) (Cover and Seal

Inspection) [35 IAC 219.123(b)(6)]:

Records that are sufficient to identify

whenever the tank is emptied for any reason

other than the transfer of liquid during

normal operation or whenever repairs are made

as a result of regular inspections or incident

of roof damage or defect.

f. When any tank is in VOL service (ethanol) the

Permittee shall maintain records and furnish reports

as required below.

i. Keep a record of each inspection performed as

required by Condition 7.4.8(c). Each record

shall identify the storage vessel on which the

inspection was performed and shall contain the

date the vessel was inspected and the observed

condition of each component of the control

equipment (seals, internal floating roof, and

fittings);

ii. If any of the conditions described in

Condition 7.4.8(c) are detected during the

annual visual inspection required, report to

the Illinois EPA within 30 days after the

inspection the identity of the storage vessel,

the nature of the defects, and the date the

storage vessel was emptied or the nature of

and date the repair was made; and

iii. After each inspection required Condition

7.4.8(c)(iii) where holes or tears in the seal

or seal fabric, or defects in the internal

floating roof, or other control equipment

defects listed in Condition 7.4.8(c) are

discovered, report to the Illinois EPA within

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30 days after the inspection the identity of

the storage vessel and the reason it did not

meet the specifications of Conditions 7.4.5(e)

or 7.4.8(c) and list each repair made [35 IAC

219.127(a)].

7.4.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected storage

tank with the permit requirements as follows, pursuant to

Section 39.5(7)(f)(ii) of the Act. Reports shall describe

the probable cause of such deviations, and any corrective

actions or preventive measures taken:

a. The Permittee shall submit written notifications and

reports to the Illinois EPA, Compliance Section as

required by the NSPS, for each affected tank, as

follows:

i. A report identifying any deficiencies or

shortcomings identified in the Annual

Inspection required by Condition 7.4.8(a)

within 30 days of inspection. This report

shall include the information specified in 40

CFR 60.115b(a)(3).

ii. A. Notification at least 30 days prior to

refilling an affected group 1 tank for

which an Out-of-Service inspection is

required by Condition 7.4.8(b)(i) to

afford the Illinois EPA with the

opportunity to have an observer present

[40 CFR 60.113b(a)(5)].

B. If the inspection is not planned and the

owner or operator of the group 1 tank

could not have known about refilling the

tank 30 days in advance, a shorter

notification may be accepted as provided

for in 40 CFR 60.113b(a)(5).

iii. A report identifying any deficiencies or

shortcomings identified in the Out-of-Service

Inspection within 30 days of the inspection

required by Condition 7.4.8(b)(i). This

report shall include the information specified

in 40 CFR 60.115b(a)(4).

b. The Permittee shall promptly notify the Illinois EPA,

Compliance Section of noncompliance with the control

and operating requirements as follows pursuant to

Section 39.5(7)(f)(ii) of the Act:

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i. Any storage of VOL in an affected tank that is

not in compliance with the control

requirements due to absence of the features

required by Condition 7.4.5, e.g., no

“secondary seal,” within five days of becoming

aware of the non-compliance status. This

notification shall include a description of

the event, the cause for the non-compliance,

actions taken to correct the non-compliance,

and the steps taken to avoid future non-

compliance.

ii. Any storage of VOL in an affected tank that is

out of compliance with the control

requirements (Condition 7.4.5) due to damage,

deterioration, or other condition of the tank,

within 30 days of becoming aware of the non-

compliance status. This notification shall

include a description of the event, the cause

for the non-compliance, actions taken to

correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

iii. Any exceedance of the emission and operational

limits shown in Conditions 7.4.6(b) and

7.4.7(b), respectively.

c. Any storage of VPL in an affected tank that is not in

compliance with the control requirements (due to

absence of the features required by Condition 7.4.5,

e.g., “no permanent submerged loading pipe,” within 5

days of becoming aware of the non-compliance status.

This notification shall include a description of the

event, the cause for the non-compliance, actions

taken to correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

d. Any storage of VPL in an affected tank that is out of

compliance with the control requirements (Condition

7.4.5) due to damage, deterioration, or other

condition of the tank, within 30 days of becoming

aware of the non-compliance status. This

notification shall include a description of the

event, the cause for the non-compliance, actions

taken to correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

7.4.11 Operational Flexibility/Anticipated Operating Scenarios

The Permittee is authorized to make the following physical

or operational change with respect to an affected storage

tanks 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

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construction permit in a timely manner for any activity

constituting construction or modification of the source,

as defined in 35 IAC 201.102:

a. Changes in the material stored in a tank, provided

the tank continues to comply with the Condition 7.4.5

of this permit.

b. The primary seals may be replaced with the same or a

different type. Secondary seals may be replaced but

must be rim-mounted.

7.4.12 Compliance Procedures

a. Emissions from each affected storage tank shall be

determined through the use of the TANKS program,

AP-42 upon which the TANKS program is based, or any

other method that utilizes USEPA approved emission

factors for storage tank emissions.

b. For the purpose of estimating HAP emissions from

equipment at the facility, the vapor wt. percent

(based on a 1992 USEPA survey or calculations based

upon the applicable MSDS for the specific VOL) of

each HAP for each product times the VOM emissions

contributed by that product is acceptable. Other

means of establishing HAP emissions utilizing USEPA

accepted methodologies is also acceptable.

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7.5 Unit 05: Wastewater Treatment System and Thermal Oxidizer

Control: None

7.5.1 Description

The wastewater treatment plant is used to treat wastewater

that is potentially contaminated with oily hydrocarbons

prior to discharge to the Mississippi River. Potential

sources of wastewater treated at the plant include

stormwater from Premcor Hartford Distribution Center or

portion of the former Premcor Hartford Refinery (now owned

by Conoco Phillips Wood River Refinery) and non-rain event

water. Non-rain event water may include, but is not

limited to: groundwater, tank bottom water, tank cleaning

water, hydrostatic test water, boiler and cooling tower

blowdown water (from Conoco Phillips) and small

miscellaneous sources including water from pump cleanings,

truck washings, etc.

7.5.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Date

Constructed/

Modified

Emission

Control

Equipment

Unit 05 Wastewater Treatment

Plant: Entry Points,

Two (2) Equalization

Tanks, Diffused Air

Flotation (DAF) Unit,

Two (2) Aeration

Basins, Two (2)

Clarifiers,

Anthracite/Sand Filter.

1973/1994* Anthracite/

Sand Filters

* Installation of two (2) equalization tanks (T-161, T-162)

7.5.3 Applicability Provisions and Applicable Regulations

a. An “affected wastewater treatment system” for the

purpose of these unit-specific conditions, is the

wastewater treatment system described in Conditions

7.5.1 and 7.5.2.

b. The affected wastewater treatment system is subject

to the emission limits identified in Condition 5.2.2.

c. i. 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 219.302,

219.303, 219.304 and the following exception:

If no odor nuisance exists the limitation of

35 IAC 218 Subpart G shall apply only to

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photochemically reactive material [35 IAC

219.301].

ii. Emissions of organic material in excess of

those permitted by Condition 7.5.3(c)(i) are

allowable if such emissions are controlled by

a flame or thermal incineration (oxidizer) so

as to either reduce such emissions to 10 ppm

equivalent methane or less, or to convert 85

percent of the hydrocarbons to carbon dioxide

and water [35 IAC 219.302(a)].

7.5.4 Non-Applicability of Regulations of Concern

a. The affected wastewater treatment system is not

subject to the NSPS for VOC Emissions From Petroleum

Refinery Wastewater Systems, 40 CFR 60 Subpart QQQ,

because the affected wastewater treatment operations

are not located at a petroleum refinery.

b. The affected wastewater treatment system is not

subject to 35 IAC 219.443, Wastewater (Oil/Water)

Separator, because the affected wastewater treatment

operations are not located at a petroleum refinery.

c. This permit is issued based on the affected

wastewater treatment system not being subject to 35

IAC 219 Subpart TT, Other Emission Units, because the

affected wastewater treatment operations do not meet

the applicability of 35 IAC 219.980(a). In

particular, the affected wastewater treatment

operations have maximum theoretical emissions of VOM

that are less than 90.7 Mg (100 tons) per year.

d. The affected wastewater treatment system is not

subject to 35 IAC 219.141(a), as applicability

requires use any single or multiple compartment

effluent water separator which receives effluent

water containing 757 l/day (200 gal/day) or more of

organic material from any equipment processing,

refining, treating, storing or handling organic

material; the affected wastewater treatment

operations do not meet this threshold.

7.5.5 Operational and Production Limits and Work Practices

a. Records addressing use of good operating practices

for the filters:

i. Records for periodic inspection of the filters

with date, name of individual performing the

inspection, and the nature of the inspection.

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ii. Records of prompt repair of defects, with

identification and description of defect,

effect on emissions, date identified, date

repaired, and nature of repair.

7.5.6 Emission Limitations

There are no specific emission limitations for this unit,

however, there are source wide emission limitations in

Condition 5.5 that include this unit.

None

7.5.7 Operating 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 wastewater treatment system to

demonstrate compliance with Conditions 5.5.1, 7.5.3,

7.5.5, 7.5.7, and 7.5.8, pursuant to Section 39.5(7)(b) of

the Act:

a. Inputs for the Water9 software in order to calculate

emissions for the affected wastewater treatment

operations;

b. The amount of wastewater treated, gal/day and

gal/year; and

c. VOM and HAP emissions (lb/month and ton/yr).

7.5.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of an affected

wastewater treatment system 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.

7.5.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

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7.5.12 Compliance Procedures

Compliance with the requirements of Condition 7.5.3(c)

(219.302) is assured by compliance with the operational

requirements of Condition 7.5.5, the monitoring

requirements of Condition 7.5.8 and the recordkeeping

requirements in Condition 7.5.9 along with the use of

software (as approved by the USEPA) to calculate emissions

from the affected wastewater treatment system.

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7.6 Unit 06: Fugitive Emissions – Paved and Unpaved Roadways

7.6.1 Description

Moving vehicles create particulate matter (road dust)

emissions on paved and unpaved roadways.

7.6.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Unit 06 Fugitive Emissions from

Paved and Unpaved Roads

---

---

7.6.3 Applicability Provisions and Applicable Regulations

Refer to the source-wide conditions in Condition 5.2.2,

which address opacity requirements.

7.6.4 Non-Applicability of Regulations of Concern

N/A

7.6.5 Control Requirements

None

7.6.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, Unit 6 is subject

to the following:

None

7.6.7 Testing Requirements

a. Upon reasonable request by the Illinois EPA, pursuant

to Section 39.5(7)(d) of the Act and 35 IAC 212.107,

for both fugitive and non-fugitive particulate matter

emissions, a determination as to the presence or

absence of visible emissions from emission units

shall be conducted in accordance with Method 22, 40

CFR part 60, Appendix A, except that the length of

the observing period shall be at the discretion of

the observer, but not less than one minute. This

test method shall be used to determine compliance

with 35 IAC 212.123 [35 IAC 212.107].

b. Upon reasonable request by the Illinois EPA, pursuant

to Section 39.5(7)(d) of the Act, measurements of

opacity shall be conducted in accordance with

Method 9, 40 CFR part 60, Appendix A, except that for

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roadways and parking areas the number of readings

required for each vehicle pass will be three taken at

5-second intervals. The first reading shall be at

the point of maximum opacity and second and third

readings shall be made at the same point, the

observer standing at right angles to the plume at

least 15 feet away from the plume and observing 4

feet above the surface of the roadway or parking

area. After four vehicles have passed, the 12

readings will be averaged. This test method shall be

used to determine compliance with 35 IAC 212.301 [35

IAC 212.109].

7.6.8 Monitoring Requirements

None

7.6.9 Recordkeeping Requirements

The Permittee shall maintain records of the following

items to demonstrate compliance with Conditions 5.5.1 and

this section pursuant to Section 39.5(7)(b) of the Act:

a. W = Mean vehicle weight (tons)

b. VMT = Vehicle miles traveled

Records for fugitive road dust shall be calculated on

an annual basis, except this calculation shall be

updated if substantial changes to the roads occur,

i.e. additional roads added.

7.6.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section of noncompliance with the permit

requirements 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.

7.6.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.6.12 Compliance Procedures

Compliance with the emission limits of section 5 shall be

based on the recordkeeping and reporting requirements in

this section and the emission factors and methods listed

below:

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a. Emissions from paved roads shall be calculated based

on the following emission factors and formulas from

Section 13.2.1 AP-42, Volume I, January, 1995:

E = k [sL/2]

0.65

[W/3]

1.5

PM emissions from unpaved roads = VMT x E

Conversion factors used: 2000 lb/ton

Note: k, sL available in Section 13.2.1 AP-42,

Volume I, January, 1995:

b. Emissions from unpaved roads shall be calculated

based on the following emission factors and formulas:

E = k [s/12]

a

[W/3]

b

/(M/0.2)

c

E is based upon the emission factor for PM from

unpaved roads from Section 13.2.2 AP-42, Volume I,

September, 1998.

PM emissions from unpaved roads = VMT x E

Conversion factors used: 2,000 lb/ton

Note: s, k, a, b, c and M are available in Section

13.2.2 AP-42, Volume I, September.

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7.7 Unit 07: Fugitive VOM Emissions from Leaking River Dock Flare

Components

Control: Leak Detection and Repair Program

7.7.1 Description

Leaking valves, flanges, seals, and miscellaneous

components are sources of fugitive VOM emissions.

The processes comprising of pumps in light liquid service,

pressure relief valves (PRV) in gas/vapor service, open-

ended valve or line, valves, all fittings, and various

fittings. The processes make up the units that are this

natural gas processing plant’s sources of fugitive VOM

emissions. While these individual fittings and processes

at the plant emit insignificant amounts of VOM emissions,

the sum of the thousands of fittings are the primary

source of VOC emissions at the plant. The procedures

outlined in

Protocol for Equipment Leak Emission Estimates

(USEPA, 1995) were used to determine fugitive VOC emission

rates for the plant. The NSPS for natural gas processing

plants, 40 CFR 60, Subpart KKK, Standards of Performance

for Equipment Leaks of VOC From Onshore Natural Gas

Processing Plants requires that a Leak Detection and

Repair (LDAR) program be instated. Expected levels of

control for the LDAR were calculated using the method

developed in Protocol for Equipment Leak Emission

Estimates (USEPA, 1995).

Fugitive emissions from equipment components, such as

valves, flanges, etc., are generated during the processing

of material through the piping distributed throughout the

source.

7.7.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Unit 07

Fugitive VOM

Emissions from

Valves, Flanges,

Seals, and

Miscellaneous

Components of River

Dock Flare

Not

Available

Leak Detection

and Repair

Program

7.7.3 Applicability Provisions and Applicable Regulations

a. The “affected Fugitive VOM Emissions from Leaking

River Dock Flare Components”, for the purpose of

these unit-specific conditions, are the emission

units described in section 7.7.1 and 7.7.2.

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b. The affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are subject to 35 IAC

219.766, Organic Material Emissions Standards and

Limitations for the Metro East Area/Leaks, since the

facility is a marine terminal as the rule

applicability requires.

c. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC Section 219.445, Organic Material Emissions

Standards and Limitations for the Metro East

Area/Leaks: General Requirements.

d. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC Section 219.446, Organic Material Emissions

Standards and Limitations for the Metro East

Area/Monitoring Program Plan for Leaks.

e. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC Section 219.447, Organic Material Emissions

Standards and Limitations for the Metro East

Area/Monitoring Program for Leaks.

f. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC Section 219.448, Organic Material Emissions

Standards and Limitations for the Metro East

Area/Recordkeeping for Leaks.

g. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC Section 219.449, Organic Material Emissions

Standards and Limitations for the Metro East

Area/Reporting for Leaks.

7.7.4 Non-Applicability of Regulations of Concern

a. The affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are not subject to 40 CFR

60, Subpart KKK, Standards of Performance for

Equipment Leaks of VOC From Onshore Natural Gas

Processing Plants since the facility is actually

classified as a Petroleum Bulk Storage and Loading

facility.

b. The affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are not subject to 40 CFR

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60 Subpart LLL, Standards of Performance for Onshore

Natural Gas Processing since the facility is

classified as a Petroleum Bulk Storage and Loading

facility.

7.7.5 Operational and Production Limits and Work Practices

None

7.7.6 Emission Limitations

In addition to Condition 5.2.2 and the source-wide

emission limitations in Condition 5.5, the affected unit

is subject to the following:

None

7.7.7 Testing Requirements

As prescribed applicable to marine terminals also by 35

IAC 219.766, affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are subject to 35 IAC Section

219.445 which prescribes that the owner or operator of a

petroleum refinery subject to 35 IAC Section 219.445 of

this Part shall, for the purpose of detecting leaks,

conduct a component monitoring program consistent with the

following provisions:

a. Test once between March 1 and June 1 of each year, by

methods referenced in Section 219.105(g) of this

Part, all pump seals, pipeline valves in liquid

service and process drains;

b. Test once each quarter of each calendar year, by

methods referenced in Section 219.105(g) of this

Part, all pressure relief valves in gaseous service,

pipeline valves in gaseous service and compressor

seals;

c. Inaccessible valves may be tested once each calendar

year instead of once each quarter of each calendar

year;

d. Observe visually all pump seals weekly;

e. Test immediately any pump seal from which liquids are

observed dripping;

f. Test any relief valve within 24 hours after it has

vented to the atmosphere; and

g. Test immediately after repair any component that was

found leaking.

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h. Storage tank valves and pressure relief devices

connected to an operating flare header or vapor

recovery device are exempt from the monitoring

requirements in subsection (a) of this Section.

i. The Illinois EPA may require more frequent monitoring

than would otherwise be required by subsection (a) of

this Section for components which are demonstrated to

have a history of leaking.

7.7.8 Monitoring Requirements

As prescribed applicable to marine terminals also by 35

IAC 219.766, affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are subject to 35 IAC Section

219.446 which provides that the owner or operator of a

petroleum refinery shall prepare a monitoring program plan

per which contains, at a minimum:

a. An identification of all refinery components and the

period in which each will be monitored pursuant to

Section 35 IAC 219.447 [35 IAC Section 219.446(a)];

b. The format for the monitoring log required by 35 IAC

Section 219.448 of this Part [35 IAC Section

219.446(b)];

c. A description of the monitoring equipment to be used

pursuant to 35 IAC Section 219.447 of this Part; and

[35 IAC Section 219.446(c)]

d. A description of the methods to be used to identify

all pipeline valves, pressure relief valves in

gaseous service and all leaking components such that

they are obvious to both refinery personnel

performing monitoring and Agency personnel performing

inspections [35 IAC Section 219.446(d)].

7.7.9 Recordkeeping Requirements

a. As prescribed applicable to marine terminals also by

35 IAC 219.766, affected Fugitive VOM Emissions from

Leaking River Dock Flare Components are subject to 35

IAC 219.448 which prescribes that the owner or

operator of a petroleum refinery shall maintain a

leaking components monitoring log which shall

contain, at a minimum, the following information:

i. The name of the process unit where the

component is located;

ii. The type of component (e.g., valve, seal);

iii. The identification number of the component;

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iv. The date on which a leaking component is

discovered;

v. The date on which a leaking component is

repaired;

vi. The date and instrument reading of the recheck

procedure after a leaking component is

repaired;

vii. A record of the calibration of the monitoring

instrument;

viii. The identification number of leaking

components which cannot be repaired until

turnaround; and

ix. The total number of components inspected and

the total number of components found leaking

during that monitoring period.

b. Copies of the monitoring log shall be retained by the

owner or operator for a minimum of two years after

the date on which the record was made or the report

prepared.

c. Copies of the monitoring log shall be made available

to the Illinois EPA, upon verbal or written request,

at any reasonable time.

7.7.10 Reporting Requirements (include reporting of deviations

from limits)

As prescribed applicable to marine terminals also by 35

IAC 219.766, affected Fugitive VOM Emissions from Leaking

River Dock Flare Components are subject to 35 IAC 219.449,

Reporting of Leaks, which provides that the owner or

operator shall:

a. Submit a report to the Agency prior to the 1st day of

both July and September listing all leaking

components identified pursuant to Section 219.447 of

this Part but not repaired within 22 days, all

leaking components awaiting unit turnaround, the

total number of components inspected and the total

number of components found leaking;

b. Submit a signed statement with the report attesting

that all monitoring and repairs were performed as

required under 35 IAC Sections 219.445 through

219.448 of this Part.

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7.7.11 Operational Flexibility/Anticipated Operating Scenarios

N/A

7.7.12 Compliance Procedures

a. Compliance with the emission limits in Conditions

5.5.1, 5.5.3, and 7.7.6 of the affected Fugitive VOM

Emissions from Leaking River Dock Flare Components

shall be based on the recordkeeping requirements in

Condition 7.7.9 and the emission factors and formulas

listed below:

i. The average emission factors for oil and gas

production operations (Table 2-4 of Protocol

for Equipment Leak Emission Estimates, 1995)

were used for calculating fugitive VOC

emissions for all fittings except valves. The

following equation was used utilizing the

fugitive emission factors:

E

VOC

= F

A

X WF

VOC

X N X 2.20 lb/kg

Where:

E

VOC

= Emission rate of VOC from all

equipment in the stream of a given

equipment type (lb/hr)

F

A

= Applicable average emission factor

for the equipment type

(kg/hr/source) from table 2-4 of

Protocol for Equipment Leak

Emission Estimates, 1995.

WF

VOC

= Average weight fraction of VOC in

the stream

N

= Number of pieces of equipment of

the applicable equipment in the

stream.

ii. For valves, a leak rate is determined from the

following equation (Table 2-10, Protocol for

Equipment Leak Emission Estimates, 1995)

Leak Rate (kg/hr/valve) = 2.29 X 10

-6

X (SV)

0.746

Where:

SV = Screening value in ppm (assumed 500 ppm

for PTE purposes; also, this is the value

certified by the manufactured that will

not be exceeded for 100,000 cycles)

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iii. Calculations of leak detection and repair

control (LDAR) effectiveness are based on the

methods in Protocol for Equipment Leak

Emission Estimates, 1995, USEPA. LDAR is

applied to pumps and valves.

b. LDAR data will be used to estimate emissions from the

affected Fugitive VOM Emissions from Leaking River

Dock Flare Components. Standard EPA methodologies

will be used for these calculations.

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7.8 Unit 08: Gasoline Storage Wells

Control: None

7.8.1 Description

The facility operates two (2) a contractor gasoline

storage tanks, gasoline tank west of main maintenance

shop, gasoline tank wells, and portable 300 gal storage

tanks.

7.8.2 List of Emission Units and Pollution Control Equipment

Emission

Unit

Description

Emission Control

Equipment

Unit 08

Gasoline Storage

None

7.8.3 Applicability Provisions and Applicable Regulations

a. The “affected Tank Wells” for the purpose of these

unit-specific conditions, are the units described in

conditions 7.8.1 and 7.8.2.

b. No person shall cause or allow the loading of any

organic material into any stationary tank having a

storage capacity of greater than 946 l (250 gal),

unless such tank is equipped with a permanent

submerged loading pipe or an equivalent device

approved by the Illinois EPA according to the

provisions of 35 IAC 201, and further processed

consistent with Section 215.108 of this Part, or

unless such tank is a pressure tank as described in

35 IAC 215.121(a) or is fitted with a recovery system

as described in 35 IAC 219.122(b) [35 IAC

219.122(b)].

c. 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 219.302, 219.303, or 219.304 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

219.301].

7.8.4 Non-Applicability of Regulations of Concern

a. The affected tank well is not subject to the NSPS for

volatile organic liquid storage vessels (including

petroleum liquid storage vessels) for which

construction, reconstruction, or modification

commenced after July 23, 1984, 40 CFR 60 Subpart Kb,

because the affected tank well was constructed prior

to 1984.

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b. The affected tank well is not subject to the

requirements of 35 IAC 219.123, petroleum liquid

storage tanks, pursuant to 35 IAC 215.123(a)(2),

which exempts storage tanks with a capacity less than

151.42 m

3

.

7.8.5 Operational and Production Limits and Work Practices

The affected tank well shall only be used for the storage

of gasoline.

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.

Emission limits for VOM are not set for the affected tank

well, as potential to emit in the absence of permit limit

is less than the significant and major source thresholds

for these pollutants pursuant to Title I of the CAA,

specifically the federal rules for the Prevention of

Significant Deterioration (PSD), 40 CFR 52.21.

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 tank well to demonstrate compliance with

Conditions 5.5.1, 7.8.3, and 7.8.5, pursuant to Section

39.5(7)(b) of the Act:

a. Design information for the tank showing the presence

of a permanent submerged loading pipe;

b. Maintenance and repair records for the tank, as

related to the repair or replacement of the loading

pipe;

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

gal/yr; and

d. The monthly and aggregate annual VOM emissions from

the affected tank well based on the material stored,

the tank throughput, and the applicable emission

factors and formulas with supporting calculations.

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7.8.10 Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section, of deviations of the affected tank

well 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. Any storage of VOL in an affected tank well that is

not in compliance with the requirements of Conditions

7.8.3(b) (see also 35 IAC 219.122(b)), e.g., no

"permanent submerged loading pipe," within thirty

days of becoming aware of the non-compliance status.

This notification shall include a description of the

event, the cause for the non-compliance, actions

taken to correct the non-compliance, and the steps

taken to avoid future non-compliance;

b. Any storage of VOL in an affected tank well that is

out of compliance with the requirements of Conditions

7.8.3(b) (see also 35 IAC 219.122(b)) due to damage,

deterioration, or other condition of the loading

pipe, within 30 days of becoming aware of the non-

compliance status. This notification shall include a

description of the event, the cause for the non-

compliance, actions taken to correct the non-

compliance, and the steps to be taken to avoid future

non-compliance;

c. The storage of any VOL or VPL other than the material

specified in Condition 7.8.5(a) within 30 days of

becoming aware of the non-compliance status. This

notification shall include a description of the

event, the cause for the non-compliance, actions

taken to correct the non-compliance, and the steps to

be taken to avoid future non-compliance.

7.8.11 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:

For the purpose of estimating VOM emissions from the

affected tank well wells to determine compliance with

Conditions 5.5.1 and 7.4.3(c), Versions 3.1 or 4.0 of the

TANKS program are acceptable.

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7.9 Unit: Lube Cubes

Control: None

7.9.1 Description

Nineteen 500-gallon double walled containers (Lube Cubes).

7.9.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Lube

Cubes

Nineteen 500-gallon

Double Walled

Containers

June 6, 2005

None

7.9.3 Applicability Provisions and Applicable Regulations

a. The “affected lube cubes” for the purpose of these

unit-specific conditions, are the units described in

Conditions 7.9.1 and 7.9.2.

b. No person shall cause or allow the loading of any

organic material into any stationary tank having a

storage capacity of greater than 946 1 (250 gal),

unless such tank is equipped with a permanent

submerged loading pipe [35 IAC 219.121(b)].

7.9.4 Non-Applicability of Regulations of Concern

The affected Lube Cubes are not subject to 40 CFR Part 64,

Compliance Assurance Monitoring (CAM) for Major Stationary

Sources, because the affected Lube Cubes do not use an

add-on control device to achieve compliance with an

emission limitation or standard.

7.9.5 Operational and Production Limits and Work Practices

Control requirements are not set for the affected Lube

Cubes. However, there may be requirements for source-wide

control requirements set forth in Condition 5.5.

7.9.6 Emission Limitations

In addition to Condition 5.3.2 and the source-wide

emission limitations in Condition 5.6, the affected Lube

Cubes are subject to the following:

a. Emissions from the lube cubes and all other emission

units at the source shall not exceed the following

limits:

Individual HAPs

Combination Of All HAPs

(Tons/Mo)

(Tons/Yr) (Tons/Mo) (Tons/Yr)

0.8

8.0

2.0

20.0

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The above limitations were established in Permit

05030053, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

addressed in the aforementioned permit does not

constitute a new major source or major modification

pursuant to Title I of the CAA, specifically 35 IAC

Part 203 [T1].

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) [T1].

b. This permit is issued based upon negligible emissions

of volatile organic material (VOM) from each lube

cube. For this purpose, emissions shall not exceed

nominal emission rates of 0.1 lb/hour and 0.18

tons/year [T1].

The above limitations were established in Permit

05030053, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

addressed in the aforementioned permit does not

constitute a new major source or major modification

pursuant to Title I of the CAA, specifically 35 IAC

Part 203 [T1].

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) [T1].

7.9.7 Testing Requirements

Testing requirements are not set for the affected Lube

Cubes. However, there are source-wide testing

requirements in Condition 5.7 and general testing

requirements in Condition 8.5.

7.9.8 Monitoring Requirements

Monitoring requirements are not set for the Lube Cubes,

however, there may be provisions for source-wide

monitoring requirements set forth in Condition 5.8 of this

permit.

7.9.9 Recordkeeping Requirements

In addition to the records required by Condition 5.9, the

Permittee shall maintain records of the following items

for the affected Lube Cubes to demonstrate compliance with

Condition 7.9.6, 5.6.1, pursuant to Section 39.5(7)(b) of

the Act:

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a. Emissions of VOM and HAPs (individual and combination

of all HAPs) from each emission unit or group of

emission units with supporting documentation and

example calculations (tons/month and tons/year).

b. As an alternative to keeping the above records, the

Permittee may keep a demonstration, which shall be

kept current, that the maximum emissions of such

operations given the maximum level of activity that

could as a practical matter, occur at the source,

would not exceed the applicable limits in Condition

7.9.6.

All records and logs required by this permit shall be

retained at a readily accessible location at the

source for at least five years from the date of entry

and shall be made available for inspection and

copying by the Illinois EPA upon request. Any

records retained in an electronic format (e.g.,

computer) shall be capable of being retrieved and

printed on paper during normal source office hours so

as to be able to respond to an Illinois EPA request

for records during the course of a source inspection.

7.9.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA,

Air Compliance Unit, of deviations of the affected

Lube Cubes 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:

i. Emissions from the affected Lube Cubes in

excess of the limits specified in Condition

7.9.6 within 30 days of such occurrence.

ii. Operation of the affected Lube Cubes in excess

of the limits specified in Condition 7.9.6

within 30 days of such occurrence.

7.9.11 Operational Flexibility/Anticipated Operating Scenarios

Operational flexibility is not set for the affected Lube

Cubes. However, there may be provisions for source-wide

operational flexibility set forth in Condition 5.11 of

this permit.

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7.9.12 Compliance Procedures

Compliance with emission limitations of Condition 7.9.6 is

addressed by meeting the requirements of Condition

7.9.3(b) and the records required in Condition 7.9.9.

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7.10 Unit 10: Storage and Barge Loading of Ethanol and Toluene

Control: River Dock Vapor Transfer/Flare System

7.10.1 Description

Storage and barge loading of Ethanol and Toluene.

7.10.2 List of Emission Units and Air Pollution Control Equipment

Emission

Unit

Description

Date

Constructed

Emission

Control

Equipment

Storage and

Barge Loading

of Ethanol and

Toluene *

Storage and

Barge Loading

of Ethanol and

Toluene

09/2004

River Dock

Vapor

Transfer/Flare

System

* This permit authorizes the Permittee to store ethanol

in the following existing floating roof tanks: 120-1,

120-2, 120-3, 120-4, 120-5, 120-8, 80-4, 80-5, 80-11,

20-8, 10-20, 5-10, 120-9, 10-5, 10-7, 10-10, and T-72.

7.10.3 Applicability Provisions and Applicable Regulations

The affected “Storage and Barge Loading of Ethanol and

Toluene” for the purpose of these unit-specific

conditions, are the processes as described in Conditions

7.10.1 and 7.10.2.

7.10.4 Non-Applicability of Regulations of Concern

Non-applicability of regulations of concern are not set

for the affected Storage and Barge Loading of Ethanol and

Toluene. However, there may be source-wide non-

applicability of regulations of concern set forth in

Condition 5.4.

7.10.5 Operational and Production Limits and Work Practices

a. Permittee shall operate and maintain tanks storing

ethanol and toluene, including associated control

features in accordance with good air pollution

control practice to minimize emissions.

b. The river dock vapor transfer/flare system shall be

operated to control VOM emissions from loading of

ethanol and toluene at all times that these materials

are being loaded at the river dock.

7.10.6 Emission Limitations

In addition to Condition 5.3.2 and the source-wide

emission limitations in Condition 5.6, the affected

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Storage and Barge Loading of Ethanol and Toluene is

subject to the following:

a. Operation of the river dock shall not exceed the

following limits:

Throughput

Material

(Barrels/Mo)

(Barrels/Yr)

Ethanol

150,000

1,500,000

Toluene

300,000

3,000,000

b. Operation of the storage facility shall not exceed a

toluene throughput of 300,000 barrels/month and

3,000,000 barrels/year.

c. Emissions attributable to the loading of ethanol and

toluene shall not exceed the following limits:

Emissions

Pollutant

(Tons/Mo)

(Tons/Yr)

VOM

0.1

0.98

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) [T1].

The above limitations were established in Permit

04070052, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

addressed in the aforementioned permit does not

constitute a new major source or major modification

pursuant to Title I of the CAA, specifically 35 IAC

Part 203 [T1].

7.10.7 Testing Requirements

Testing requirements are not set for the affected Storage

and Barge Loading of Ethanol and Toluene, however, there

are source-wide testing requirements in Condition 5.7 and

general testing requirements in Condition 8.5.

7.10.8 Monitoring Requirements

Monitoring requirements are not set for the affected

Storage and Barge Loading of Ethanol and Toluene.

However, there may be provisions for source-wide

monitoring requirements set forth in Condition 5.8 of this

permit.

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7.10.9 Recordkeeping Requirements

In addition to the records required by Condition 5.9, the

Permittee shall maintain records of the following items

for the affected Storage and Barge Loading of Ethanol and

Toluene to demonstrate compliance with Condition 7.10.6,

and 5.6.1, pursuant to Section 39.5(7)(b) of the Act:

The Permittee shall maintain the following records:

a. Properties of the ethanol and toluene materials

handled at the facility, as needed to calculate VOM

emissions from handling such materials with

supporting documentation.

b. Identification and throughput (barrels/month) for

each type of material stored in each tank;

c. Identification and throughput (barrels/month) of each

material loaded at the river dock;

d. i. VOM emissions from the storage of ethanol and

toluene (tons/month and tons/year), with

supporting calculations.

ii. VOM emissions from the loading of ethanol and

toluene (tons/month and tons/year), with

supporting calculations.

7.10.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA,

Air Compliance Unit, of deviations of the affected

Storage and Barge Loading of Ethanol and Toluene 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:

i. Emissions from the affected Storage and Barge

Loading of Ethanol and Toluene in excess of

the limits specified in Condition 7.10.6

within 30 days of such occurrence.

ii. Operation of the affected Storage and Barge

Loading of Ethanol and Toluene in excess of

the limits specified in Condition 7.10.6

within 30 days of such occurrence.

7.10.11 Operational Flexibility/Anticipated Operating Scenarios

This permit authorizes the Permittee to store toluene in

any two existing floating roof tanks.

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7.10.12 Compliance Procedures

a. Compliance with the limitations of Condition 7.10.6

is addressed by the requirements of Condition 7.10.5

and the records required in Condition 7.10.9.

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7.11 Unit 11: Soil Vapor Extraction System

Control: Thermal Oxidizer

7.11.1 Description

The soil vapor extraction system will be installed to

extract hydrocarbon vapors present in the soil using a

series of extraction wells. The system consist of a

blower which will draw vapors from the wells to a thermal

oxidizer.

7.11.2 List of Emission Units and Air Pollution Control Equipment

Emission Unit

Description

Date

Constructed

Emission

Control

Equipment

Soil Vapor

Extraction

System

Blowers, Ancillary

Equipment

1/2006

Thermal

Oxidizer

7.11.3 Applicability Provisions and Applicable Regulations

a. The “affected unit” for the purpose of these unit-

specific conditions, is the soil vapor extraction

system described in Conditions 7.11.1 and 7.11.2.

b. The affected unit is subject to 35 IAC Part 219,

Subpart TT: Other Emission Units.

c. i. The affected unit is subject to 35 IAC

219.301: Use of Organic Material, which

provides that:

No person shall cause or allow the discharge

of more than 3.6 kg/hr (8 lbs/hr) of organic

material into the atmosphere from any emission

unit, except as provided in 35 IAC 219.302 and

the following exception: If no odor nuisance

exists the limitation of this Subpart shall

apply only to photochemically reactive

material.

ii. Emissions of organic material in excess of

those permitted by 35 IAC 219.301 are

allowable if such emissions are controlled by

thermal incineration so as either to reduce

such emissions to 10 ppm equivalent methane

(molecular weight 16) or less, or to convert

85 percent of the hydrocarbons to carbon

dioxide and water.

d. Pursuant to 35 IAC 212.123(a), no person shall cause

or allow the emission of smoke or other particulate

matter, with an opacity greater than 30 percent, into

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the atmosphere from any emission unit other than

those emission units subject to the requirements of

35 IAC 212.122, except as allowed by 35 IAC

212.123(b) and 212.124.

7.11.4 Non-Applicability of Regulations of Concern

This permit is issued based upon the affected unit not

being subject to the 40 CFR Part 63 Subpart GGGGG:

National Emission Standards for Hazardous Air Pollutants:

Site Remediation because the source is not a major source

of HAP [40 CFR 63.7881(a)].

7.11.5 Operational and Production Limits and Work Practices

a. The emission capture and control equipment shall

achieve an overall reduction in uncontrolled VOM

emissions of at least 81 percent from each affected

unit, pursuant to 35 IAC 219.986(a).

Note: This control requirement is less stringent

than the control requirement listed in Condition

7.11.3(c)(ii).

b. The thermal oxidizer shall be in operation at all

times when the affected unit is in operation and

emitting air contaminants.

c. The thermal oxidizer combustion chamber shall be

preheated to at least the manufacturer’s recommended

temperature but no less than the temperature at which

compliance was demonstrated in the most recent

compliance test, or 1400°F in the absence of a

compliance test. This temperature shall be

maintained during operation.

d. Natural gas shall be the only fuel fired in the

thermal oxidizer.

e. The maximum gas flow rate to the thermal oxidizer

shall not exceed 750 cfm.

7.11.6 Emission Limitations

a. Emissions from the affected unit shall not exceed the

following limits. Compliance with annual limits shall

be determined from a running total of 12 months of data.

Emissions

Pollutant

(Tons/Month) (Tons/Year)

NO

x

----

3.85

CO

0.27

3.24

VOM

----

7.84

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b. This permit is issued based upon negligible emissions

of SO

2

, PM and PM

10

from the affected unit. For this

purpose, emissions of all such pollutants shall not

exceed a nominal emission rate of 0.1 lb/hour and

0.44 tons/year combined.

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) [T1].

The above limitations were established in Permit

05120034, pursuant to 35 IAC Part 203. These limits

ensure that the construction and/or modification

addressed in the aforementioned permit does not

constitute a new major source or major modification

pursuant to Title I of the CAA, specifically 35 IAC

Part 203 [T1].

7.11.7 Testing Requirements

a. When in the opinion of the Agency it is necessary to

conduct testing to demonstrate compliance with 35 IAC

219.986, the owner or operator of a VOM emission unit

subject to the requirements of 35 IAC Part 219,

Subpart TT shall, at his own expense, conduct such

tests in accordance with the applicable test methods

and procedures specified in 35 IAC 219.105 [35 IAC

219.988(a)].

b. Nothing in 35 IAC Part 219 shall limit the authority

of the USEPA pursuant to the Clean Air Act, as

amended, to require testing [35 IAC 219.988(b)].

7.11.8 Monitoring Requirements

The Permittee shall use Illinois EPA approved continuous

monitoring equipment which shall be installed, calibrated,

maintained, and operated according to vendor

specifications at all times the afterburner is in use.

The continuous monitoring equipment shall monitor the

combustion chamber temperature of each afterburner.

7.11.9 Recordkeeping Requirements

a. The Permittee shall collect and record all of the

following information each day and maintain the

information at the source for a period of three

years:

i. Control device monitoring data.

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ii. A log of operating time for the capture

system, control device, monitoring equipment

and the associated emission source.

iii. A maintenance log for the capture system,

control device and monitoring equipment

detailing all routine and non-routine

maintenance performed including dates and

duration of any outages.

b. The Permittee shall maintain a file for the affected

unit documenting the following:

i. Maximum rated exhaust flow rate from the

affected unit, as exhausted to the thermal

oxidizer (CFM);

ii. Maximum VOM concentration in uncontrolled

exhaust (ug/L);

iii. Maximum rated burner capacity of the thermal

oxidizer (mmBtu/hour); and

iv. Potential NO

x

and CO emissions from the

affected unit, with supporting documentation

and calculations.

c. The Permittee shall maintain records of the VOM

emissions (tons/month and tons/year) with supporting

calculations and documentation.

7.11.10 Reporting Requirements

a. The Permittee shall promptly notify the Illinois EPA,

Air Compliance Unit, of deviations of an the affected

unit with the permit requirements as follows.

Reports shall describe the probable cause of such

deviations, and any corrective actions or preventive

measures taken.

b. The Permittee shall notify the Illinois EPA in the

following instance [35 IAC 219.991(a)(3)]:

i. Any record showing a violation of the

requirements of 35 IAC Part 219, Subpart PP,

QQ, RR or TT shall be reported by sending a

copy of such record to the Illinois EPA within

30 days following the occurrence of the

violation.

7.11.11 Operational Flexibility/Anticipated Operating Scenarios

Operational flexibility is not set for the affected unit.

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7.11.12 Compliance Procedures

a. Compliance with the VOM emission limit in Condition

7.11.6 shall be based on the recordkeeping

requirements in Condition 7.11.9 and the following

equation:

VOM Emissions = Blower Discharge Rate (cfm) x

28.31685 L/cf x 60 min/hour x VOM

concentration (ug/L) x (1/10

9

kg/ug) x 2.20462

lb/kg x (1- overall control efficiency/100)

b. Compliance with the NO

x

and CO emission limits in

Condition 7.11.6 shall be determined by appropriate

emission factors and the recordkeeping requirements

in Condition 7.11.9.

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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

May 27, 2006

(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 that contravene express permit terms

without applying for or obtaining an amendment to this

permit, provided that [Section 39.5(12)(a)(i) of the

Act]:

a. The changes do not violate applicable requirements;

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b. The changes do not contravene federally enforceable

permit terms or conditions that are monitoring

(including test methods), recordkeeping, reporting,

or compliance certification requirements;

c. The changes do not constitute a modification under

Title I of the CAA;

d. Emissions will not exceed the emissions allowed under

this permit following implementation of the physical

or operational change; and

e. 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. This notice shall:

i. Describe the physical or operational change;

ii. Identify the schedule for implementing the

physical or operational change;

iii. 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;

iv. Provide emission calculations which

demonstrate that the physical or operational

change will not result in a modification; and

v. 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.

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8.6 Reporting Requirements

8.6.1 Monitoring Reports

If monitoring is required by any applicable requirements

or conditions of this permit, a report summarizing the

required monitoring results, 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

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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

2009 Mall Street

Collinsville, Illinois 62234

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iii. Illinois EPA - Air Permit Section

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section (MC 11)

P.O. Box 19506

Springfield, Illinois 62794-9506

iv. USEPA Region 5 - Air Branch

USEPA (AE - 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.

8.7 Obligation to Comply with Title I Requirements

Any term, condition, or requirement identified in this permit by

T1, T1R, or T1N is established or revised pursuant to 35 IAC Part

203 or 40 CFR 52.21 (“Title I provisions”) and incorporated into

this permit pursuant to both Section 39.5 and Title I provisions.

Notwithstanding the expiration date on the first page of this

permit, the Title I conditions remain in effect pursuant to Title

I provisions until the Illinois EPA deletes or revises them in

accordance with Title I procedures.

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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.

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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)(a) and

(p)(ii) of the Act and 415 ILCS 5/4]:

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

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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 authorized by this permit; 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 authorized

by this permit.

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

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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 annual compliance certifications. The compliance

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certifications shall be submitted no later than May 1 or more

frequently as specified in the applicable requirements or by

permit condition. The compliance certifications shall be

submitted to the Air Compliance Section, Air Regional Field

Office, and USEPA Region 5 – Air Branch. The addresses for the

submittal of the compliance certifications are provided in

Condition 8.6.4 of this permit.

a.

The certification shall include the identification of each

term or condition of this permit that is the basis of the

certification; the compliance status; whether compliance

was continuous or intermittent; the method(s) used for

determining the compliance status of the source, both

currently and over the reporting period consistent with

the conditions of this permit.

b.

All compliance certifications shall be submitted to USEPA

Region 5 in Chicago as well as to the Illinois EPA.

c.

All compliance reports required to be submitted shall

include a certification in accordance with Condition 9.9.

9.9 Certification

Any document (including reports) required to be submitted by this

permit shall contain a certification by a responsible official of

the Permittee that meets the requirements of Section 39.5(5) of

the Act [Section 39.5(7)(p)(i) of the Act]. An example

Certification by a Responsible Official is included as an

attachment to this permit.

9.10 Defense to Enforcement Actions

9.10.1 Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an

enforcement action that it would have been necessary to

halt or reduce the permitted activity in order to maintain

compliance with the conditions of this permit [Section

39.5(7)(o)(ii) of the Act].

9.10.2 Emergency Provision

a. An emergency shall be an affirmative defense to an

action brought for noncompliance with the technology-

based emission limitations under this permit if the

following conditions are met through properly signed,

contemporaneous operating logs, or other relevant

evidence:

i. An emergency occurred as provided in Section

39.5(7)(k) of the Act and the Permittee can

identify the cause(s) of the emergency.

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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].

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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